Peir v. Commissioner of Internal Revenue

Review of a decision of the Board of Tax Appeals that “petitioners are jointly and severally liable as transferees * * * for a deficiency of $14,976.55 in the income tax” of Western Oxygen Company for 1929, is sought by the petition before us.

Petitioners were, at the material times herein, stockholders of the Western Oxygen Company, hereinafter called Western Oxygen, a Delaware corporation, which had both common and preferred stock outstanding. The Board found: “ * * * The preferred stock was redeemable on any dividend date at $105 per share plus all accumulated and unpaid dividends thereon.…