Frazer v. Commissioner of Internal Revenue

I believe the previous ruling of this court in Commissioner v. Alldis’ Estate, 6 Cir., 140 F.2d 885 is applicable and should be followed.

It was there held that the amount received by the Administrator for the certificates owned by the decedent resulted in a capital gain rather than receipt of income. The interest of the owner of certificates is the same regardless of how that interest is terminated, by death or by termination of employment. In either event that interest ceases and is liquidated. I see no material difference in its liquidation by transfer to the corporation, as in the Alldis…