Singleton Et Ux. v. Commissioner of Internal Revenue

Mr. Justice Blackmun, with whom Mr. Justice Marshall and Mr. Justice Powell join,

dissenting.

The issue in this federal income tax case is whether a cash distribution that petitioner husband (hereafter petitioner) received in 1965 with respect to his shares in Capital Southwest Corporation (CSW) was taxable to him as a dividend, as the United States Court of Appeals for the Fifth Circuit held, or whether that distribution was a return of capital and therefore not taxable, as the Tax Court held. I regard the issue as of sufficient importance in the administration of the income tax laws to…