Commissioner of Internal Revenue v. Johnson

The Commissioner of Internal Revenue determined a deficiency in the income tax of respondent, Earle F. Johnson, for the year 1935, in the amount of $31,534.38. The Board of Ta.x Appeals reduced this deficiency assessment to $594.47; and the Commissioner has petitioned this court for review.

The sole question to be determined is whether the respondent taxpayer received, within the purview of Section 115(c) of the Revenue Act of 1934, 26 U.S.C.A. Int.Rev. Acts, page 703,1 a distribution in liquidation of the Great Miami Realty Corporation, an Ohio corporation in which he was a stockholder. If…