W. Bladen Lowndes and Anne W. Lowndes v. United States

SOBELOFF, Circuit Judge:

The question presented by this appeal is whether the taxpayer realized ordinary income when she purchased all. of the outstanding stock of each of four corporations or whether she received income, taxable either as long term capital gain or as ordinary income, at the time of liquidation, more than six months after the acquisition of the stock of each corporation. The stock purchases were made in Mrs. Lowndes’ name only, but the tax returns for 1957, 1959 and 1960, the years in question, were filed jointly by Mr. Lowndes and his wife.

The four corporations, subsidiaries…