Estate of E. J. Van Heusden, Deceased Transferee v. Commissioner of Internal Revenue

TUTTLE, Chief Judge:

This is an appeal by the appellants, as transferees, of a corporation, West Cocoa Acres, Inc., now liquidated, from a decision of the Tax Court establishing an income tax deficiency for the taxable year 1958, against the corporation in the amount of $65,608.01. The findings of fact and opinion of the Tax Court are reported at 44 T.C. 491.

The question presented here is whether the Tax Court correctly held that the corporation which was formed in order to acquire an option owned by the individual stockholders to purchase and then carry out an offer already received by the…