Burton W. Doyle v. District of Columbia

DANAHER, Circuit Judge:

The taxpayer in 1963 was the majority stockholder in Doyle Printing & Offset Company, Inc., hereinafter the Corporation. On December 29, 1963, he transferred to that Corporation 3,170 of its shares for which he then received $40,000 in cash and a promissory note for $181,900. 1 The District of Columbia tax authorities assessed a deficiency in income tax of $9,260 plus interest which the taxpayer paid under protest. The District of Columbia Tax Court decided that the payment by the Corporation constituted a dividend as defined in section 47-1551e(m) D.C.Code (1961), and…