Clemmons v. Commissioner of Internal Revenue

SIBLEY, Circuit Judge.

These are petitions by Sol E. Gordon and J. C. ■ Clemmons and the wife of each to review a decision of the Board of Tax Appeals • whereby each petitioner was held to have realized a taxable gain during the year 1925 in •a transaction involving the transfer to Saenger Amusement Company of one-half of the capital stock of the Jefferson Amusement Company; the other half being retained by the petitioners. The two wives are concerned because of the community property laws of Texas, but they do not figure otherwise in the transaction. Gordon and Clemmons owned the entire five…