C. Blake McDowell Inc. v. Commissioner of Internal Revenue

ORDER

The Commissioner appeals from a decision of the Tax Court finding no deficiencies in the appellee taxpayer’s taxes for the taxable years 1972 and 1973. C. Blake McDowell, Inc. v. Commissioner, 67 T.C. 1043 (1977). The issue presented to the Tax Court was the validity of Treas.Reg. § 1.562-l(a) which provides, inter alia, that when a personal holding company distributes appreciated property to its shareholders as deficiency dividends, the amount of a claimed deficiency dividend deduction for the property is limited to the adjusted basis of the property at the time of distribution. The Tax…