Olson v. Commissioner

SUPPLEMENTAL OPINION

Withey, Judge:

The petitioners on October 17,1967, filed a motion, which respondent has approved, to revise the opinion (48 T.C. 855) filed herein on September 21,1967.

As we understand the motion, the parties are now in agreement that the distribution by Cleveland of the 12 shares of Buffalo stock of which Sidal became the equitable owner but for which stock certificates were issued directly to Albert Schultz and Sidney Olson constituted dividends to those two persons only to the extent that the "fair market value of such shares did not exceed the accumulated earnings and…