Blum v. Commissioner

OPINION.

HakROn, Judge:

The only question before us is whether the amounts received by petitioner from the corporation in each of the taxable years were distributions in partial liquidation within the meaning of section 115 (c) of the Internal Revenue Code,1 as respondent contends, or whether the amounts were received through a purchase of the stock by the corporation as petitioner contends. If the transaction falls within section 115 (c), the full amount of the gain realized by petitioner is taxable to her, whereas if the transaction merely constituted a sale to the corporation, only 50…