Old Colony Trust Co. v. Commissioner of Internal Revenue

WILSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals, and involves the income taxes of Charles J. Shugrue, now deceased, for the calendar year of 1923.

The decedent was the principal stockholder in the Crown Shade & Screen Company, a Massachusetts corporation engaged in the manufacture and sale of window shades and screens. The capital stock of the corporation outstanding prior to 1923 was only $9,700, divided into 97 shares of the par value of $100, and was held by the officers of the company, four in number, Mr. Shugrue holding 75 shares.

The policy of…