Hill v. COMMISSIONER OF INTERNAL REVENUE

ERNEST F. COCHRAN, District Judge.

The petition to review the decision of the Board of Tax Appeals in this case raises the question whether the sum of $25,000, received by the taxpayer from Union Bleaehery, a South Carolina corporation, in the year 1927, should be considered a dividend under section 201 (g) of the Revenue Act of 1926, 44 Stat. 10, 11 (26 USCA § 932 (g), or a distribution in partial liquidation of the corporation, under section 201 (c) of that act (26 USCA § 932 (e).

Union Bleaehery was incorporated on or about July 1,1922, with an authorized capital stock of the par value of…