Kaufmann v. Commissioner of Internal Revenue

MARIS, Circuit Judge.

These cases present again the question, much litigated in recent years, 1 as to whether a sale of corporate property which is ■consummated by the stockholders through the liquidation of the corporation and the subsequent conveyance by them of the corporate property to the purchaser is to be regarded as a ‘sale by the corporation for the purposes of federal income tax.

'Columbia Holding Corporation, the corporation with which we are here concerned, was incorporated under the laws of Pennsylvania to hold title to an apartment house in Pittsburgh, Pennsylvania, known as the…