Chester A. Snow v. District of Columbia, Chester A. Snow, T/a Chester A. Snow Rents v. District of Columbia

PRETTYMAN, Senior Circuit Judge.

Appellant Snow bought from one Guy all the stock in Lombardy, Inc., and paid him for it $1,000,000 in cash and a secured note. 1 Immediately thereafter he (Snow), as the sole stockholder, liquidated the corporation, transferring to himself all the assets. These were of various sorts, of a total fair value of $1,-000. 000. On the books of Lombardy $300,000 of these assets appeared as an earned surplus, that is, accumulated corporate earnings.

The District of Columbia Tax Assessor levied income taxes upon Snow on account of the transaction. The District of…