Stoner v. Commissioner of Internal Revenue

DAVIS, Circuit Judge.

On April 3, 1929, the taxpayer, Blaine L. Stoner, entered into an agreement, which he executed, on behalf of the stockholders of the Suburban Water Company, whereby the stock of the company was to be sold on terms for the sum of $1,250,000. The agreement provided, among its several terms: “To Insure the fulfillment of the Seller’s obligations created in the next preceding subparagraph hereof, Seller agrees to deduct from the amount of the purchase price payable hereunder a sum which shall not be less than $50,000, and to deposit said sum in a bank of the Seller’s…