Estate of Uris v. Commissioner

OAKES, Circuit Judge:

The question presented by this appeal is unusually complicated: whether a corporate distribution is out of “earnings and profits” and thus fully taxable to the distributees as dividends. The distributees were Percy Uris, now deceased, and Harold Uris; and the tax liability here involved is for each of them and their wives as co-signers of separate joint tax returns, collectively hereinafter referred to as “taxpayers.” On March 26, 1969, Uris Lexington, Inc., which is a real estate corporation in New York City and a taxpayer on a calendar year basis, made the distribution…