Wichita Term. El. Co. v. Commissioner of Int. R.

BRATTON, Circuit Judge.

The question presented is whether gain from the sale of certain properties was attributable to a corporation or to its former stockholders.

Section 22 of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 22, in material part, defines gross income to include gains, profits, and income derived *514from trades, businesses, commerce, or sales, or dealings in real or personal property, growing out of the ownership and use of such property; also from the transaction of any business carried on for gain or profit, or gains or profits and income derived from any source whatever;…