Estate of Don Murillo Brockway, Deceased v. Commissioner of Internal Revenue

JAMES ALGER FEE, Circuit Judge.

In 1922 there was incorporated Crown Body & Coach Corporation with 200 shares of common stock, of which Don Murillo Brockway 1 owned 100. Murillo M. Brockway, his son,* became an employee of Crown. In 1936 decedent acquired for Murillo the outstanding 100 shares of stock, for the purchase price of which his son subsequently reimbursed him. In the same year, decedent and Murillo entered into a written agreement to place this stock in “themselves as joint tenants.” Subsequently, 550 shares of common and 950 shares of preferred stock were issued by Crown, in…