Howard P. Blount and Dolly H. Blount v. Commissioner of Internal Revenue

FRIENDLY, Circuit Judge:

This case concerns redemptions of stock of the Blount Lumber Company, organized in 1908 by the father of taxpayer, Howard Blount. 1 On his death in 1932, the father left majority control to his widow. Although she became president, the business was conducted by Howard Blount, his brother H. Floyd Blount, and their brother-in-law, H. Wallace Parker. Since 1950 the three men and their families have owned substantially all the stock.

During the early 1950’s Howard’s son George, Floyd’s son F. Thomas, and Wallace’s son Robert became active in the company. After some…