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RAFFERTY v. C. I. R.

No. 71-1121.

452 F.2d 767 (1971)

Joseph V. RAFFERTY et al., Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided December 6, 1971.

Attorney(s) appearing for the Case

Robert J. McDonough, Boston, Mass., with whom Daniel S. Fischbach and Herrick, Smith, Donald, Farley & Ketchum, Boston, Mass., were on brief, for petitioners, appellants.

David English Carmack, Atty. Tax Div., Dept. of Justice, with whom Johnnie M. Walters, Asst. Atty. Gen., Myer Rothwacks, and Elmer J. Kelsey, Attys. Tax Div., Dept. of Justice, were on brief, for respondent, appellee.

Before ALDRICH, Chief Judge, and McENTEE and COFFIN, Circuit Judges.

McENTEE, Circuit Judge.

Taxpayers, Joseph V. Rafferty and wife, appeal from a decision of the Tax Court, 55 T.C. 491, which held that a distribution to them of all the outstanding stock of a real estate holding corporation did not meet the requirements of § 355 of the Internal Revenue Code of 1954 and therefore was taxable as a dividend. Our opinion requires a construction of § 355 and the regulations thereunder.1

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