William J. Haag and Edith C. Haag v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. E. B. Sewall Manufacturing Company

MATTHES, Circuit Judge.

Case No. 17,585 involves an income tax deficiency assessment against petitioners William J. Haag and Edith C. Haag for the calendar year 1957. The Commissioner of Internal Revenue determined the deficiency to be $110,313.88, and the Tax Court — after trial — found the deficiency amounted to $50,666.05. The theory of the Commissioner and the Tax Court is that William J. Haag (Haag) realized ordinary income as the result of a transaction whereby he became reinvested with record title to certain real estate from E. B. Sewall Manufacturing Company (Company) on September 1,…