Ned Bord and Anne R. Bord v. District of Columbia

J. SKELLY WRIGHT, Circuit Judge:

This is a petition for review of a decision of the District of Columbia Tax Court upholding an assessment of deficiency in petitioners’ District of Columbia income taxes for the year 1958. The questions raised on appeal are (1) whether amounts received by a stockholder as proceeds from the sale of corporate property are taxable as dividends under 47 D. C.Code § 1551e(m) (1961); (2) whether petitioners were entitled in their 1958 return to a deduction for bad debts; and (3) whether petitioners should be assessed a negligence penalty for their failure to report…