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PIEDMONT CORPORATION v. C. I. R.

No. 11311.

388 F.2d 886 (1968)

The PIEDMONT CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided January 4, 1968.

Attorney(s) appearing for the Case

Claude C. Pierce, Greensboro, N. C. (Charles B. Robson, Jr., and McLendon, Brim, Brooks, Pierce & Daniels, Greensboro, N. C., on brief) for petitioner.

Donald Williamson, Atty., Dept. of Justice (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson and Robert N. Anderson, Attys., Dept. of Justice, on brief) for respondent.

Before SOBELOFF, BOREMAN and WINTER, Circuit Judges.

WINTER, Circuit Judge:

The essential question we must decide is whether the assignment to the taxpayer of certain option rights held by its sole stockholders in return for $10,000 cash and $160,000 in unsecured promissory notes constituted a bona fide sale or a contribution to capital.1 The Tax Court concluded that the successive transfers of the option were in effect a contribution of capital and that the promissory

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