LUCKMAN v. COMMISSIONER

Docket No. 3959-65.

56 T.C. 1216 (1971)

SID LUCKMAN AND ESTELLE LUCKMAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 31, 1971.


Attorney(s) appearing for the Case

George V. Delson and Arnold Broser, for the petitioners.

Lawrence Shongut and Stanley J. Goldberg, for the respondent.


SUPPLEMENTAL OPINION

FORRESTER, Judge:

The issue presented for our decision is to what extent petitioners' receipt in 1961 of $37,245.75 from Rapid American Corporation (hereinafter referred to as Rapid) was a taxable dividend.

Originally that issue turned upon the resolution of one principal question and three subsidiary questions. On November 12, 1968, in accordance with our opinion of July 24, 1968, reported at 50 T.C. 619...

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