Schinebro, Inc. v. Commissioner of Internal Revenue

CHASE, Circuit Judge.

■ Schinebro, Inc., is a personal holding; company whose stock is wholly owned by two brothers, J. M. and L. W. Schine. Om *505August 15, 1936, the brothers Schine as directors of the company - declared themselves a dividend of $15,000 for the year 1936. The dividend was to be paid by a distribution of 1000 shares of Texas and Pacific Coal and Oil Company and the allocation of cash, already received by the brothers in January and February of 1936, to make up the difference in the value of the Texas stock and the declared dividend. The cash payments when originally received…