Jordanos', Inc., Madeline F. Jordano, Howard H. King and Delfina I. King, Helen M. Jordano v. Commissioner of Internal Revenue

This case is before us pursuant to section 7482 of the Internal Revenue Code of 1954, which authorizes our review of de cisions of the Tax Court of the United States. Several taxpayers have petitioned for review of four consolidated Tax Court decisions in favor of the Commissioner of Internal Revenue. The decisions, which concern the petitioners’ income tax liability for the years 1958 to 1961, inclusive, turn on a finding that payments made by the corporate petitioner to three of the individual petitioners represented dividends, and not gifts or compensatory pensions.

We think that that…