Sorin v. Commissioner
United States Tax Court
1. Reliance at the hearing on section 117 (m), I. R. C. 1939, held, not "new matter" shifting the burden of proof to respondent in a proceeding where the deficiency was determined generally under the provisions of I. R. C. 1939. Thomas Wilson, 25 T. C. 1058, distinguished. 2. Petitioners held, on the facts, not to have proved that amounts received were not distributions from a collapsible corporation under section 117 (m), I. R. C. 1939. Raymond G. Burge, 28 T. C. 246; J. D.…
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1. Reliance at the hearing on section 117 (m), I. R. C. 1939, held, not "new matter" shifting the burden of proof to respondent in a proceeding where the deficiency was determined generally under the provisions of I. R. C. 1939. Thomas Wilson, 25 T. C. 1058, distinguished. 2. Petitioners held, on the facts, not to have proved that amounts received were not distributions from a collapsible corporation under section 117 (m), I. R. C. 1939. Raymond G. Burge, 28 T. C. 246; J. D. Abbott, 28 T. C. 795. 3. Basis of stock upon which the distribution was made, held, on the facts, to be the amount…
1Opinion of the Court
Arthur Sorin and Henrietta A. Sorin, Petitioners, v. Commissioner of Internal Revenue, Respondent
Sorin v. Commissioner
Docket No. 56400
United States Tax Court
29 T.C. 959; 1958 U.S. Tax Ct. LEXIS 250;
February 26, 1958, Filed
Decision will be entered under Rule 50.
1. Reliance at the hearing on section 117 (m), I. R. C. 1939, held, not "new matter" shifting the burden of proof to respondent in a proceeding where the deficiency was determined generally under the provisions of I. R. C. 1939. Thomas Wilson, 25 T. C. 1058, distinguished.
2. Petitioners held, on the facts, not to have proved that…
2Cases cited7 opinions
- Helvering v. GowranSupreme Court of the United States · 1937
- Helvering v. WoodSupreme Court of the United States · 1940
- Abbott v. CommissionerUnited States Tax Court · 1957
- Burge v. CommissionerUnited States Tax Court · 1957
- Bair v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
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