MacDonald v. Commissioner of Internal Revenue

MANTON, Circuit Judge.

This petition seeks a review of income taxes assessed for the years 1928 and 1929. Appellant, owner of all the common stock, 1,500 shares, of the Lockwood Trade Journal Company, Inc., contracted to purchase 1,425 shares of the preferred stock of that company, on July 10, 1928. He paid therefor $62,700 in cash, and executed and delivered Series A notes for a total sum of $128,250; a Series B note for $80,000; and Series C notes for $51,300, as agreed. A new certificate for the 1,425 shares of preferred stock was issued to him, which he indorsed in blank and deposited with…