Snider v. United States

ALDRICH, District Judge.

The petitioners sue for refund of income taxes for the taxable year 1950. The only question is a single one on the merits. The facts have been stipulated and I find them to be in accordance with the stipulations filed by the parties and supplemented orally in open court.

In 1947 petitioners were substantial shareholders in the Braemore-Kenmore Trust, a Massachusetts trust having transferable shares. In that year the trust was reorganized into a newly-formed corporation, the Hotel Kenmore Corporation.* All the assets of the trust were transferred to the corporation which…