Ruth T. Lengsfield, Coralie Mayer Lengsfield and Blanche L. Brown v. Commissioner of Internal Revenue

HUTCHESON, Chief Judge.

This appeal involves deficiencies in income tax determined by the Commissioner against the taxpayers for the calendar years 1947 to 1950, and sustained by the Tax Court in findings of fact 1 and an opinion not officially reported.

The sole question presented is whether the Tax Court erred in holding that monthly payments received by taxpayers from a corporation in which they held stock constituted distributions of corporate earnings taxable to the recipients as dividends rather than non-taxable gratuities.

In support of its ultimate conclusion, that the monthly payments…