Robert H. Storz, Transferee of Storz-Wachob-Bender Co., a Dissolved Corporation v. Commissioner of Internal Revenue

MacLAUGHLIN, District Judge.

The Commissioner appeals from a decision of the Tax Court holding that certain uncompleted underwriting contracts assigned in the complete liquidation of appel-lee’s business were property within the meaning of Section 337 of the Internal Revenue Code (26 U.S.C. § 337), but that the assignment of income doctrine, which would make the appellee responsible for payment of income tax on a part of the purchase price, was not applicable under the facts of this case. While we agree that the contracts were property under Section 337, we hold that the assignment of income…