Commissioner of Internal Revenue v. Estate of Goldstein

SMITH, Circuit Judge:

This is a petition by the Commissioner -of Internal Revenue for review of a decision of the Tax Court of the United States, Withey, J., granting taxpayers’ petition for redetermination of deficiency in individual income tax for 1950 assessed by Commissioner. Taxpayers are the executors of the estate of Abraham ■Goldstein, and Anna, his widow. In 1950 Abraham and his wife, Anna were the shareholders in A & A Corporation, an insurance agency. In that year on dissolution of the corporation they were distributees of its assets, including the right to renewal commissions on…