Jeffries v. Commissioner of Internal Revenue

HUTCHESON, Circuit Judge.

In 1940, petitioner was the owner of half the stock, and president, of Girard Realty Co. In that year, pursuant to an arrangement made between her and the owners of the other half of the stock, the corporation transferred to petitioner one-half of its lands and property, and petitioner surrendered to the corporation for cancellation her one-half of the stock: Considering the properly received by her in exchange for the stock as received in a complete liquidation of the corporation and her gain therefrom long term capital gain, petitioner returned it that way. The…