Beatrice Levin v. Commissioner of Internal Revenue

IRVING R. KAUFMAN, Circuit Judge:

The perils of acting without competent tax advice 1 2are demonstrated anew, if further evidence be needed, by this petition to review a decision of the Tax Court, 47 T.C. 258 (1966), holding that distributions in 1960, 1961, 1962, and 1963 to the taxpayer in redemption of her stock in a family corporation were “essentially equivalent to a dividend” within the meaning of section 302(b) (1) of the Internal Revenue Code of 1954, and hence taxable at ordinary income rates. 2 We affirm the decision of the Tax Court.

The evidence, as found by the Tax Court, 3…