C. A. Sammons, Individually and as Independent of the Estate of Rosine S. Sammons, Deceased v. United States

LEWIS R. MORGAN, Circuit Judge:

In this federal income tax ease appellant-taxpayer claims a refund for taxes paid on an alleged constructive dividend which arose when stock was transferred between corporations either owned outright or controlled by the taxpayer. The jury below found that the stock was transferred at a price well below fair market value, and the trial judge entered judgment against the taxpayer. We affirm.

In December of 1957, Sammons, the taxpayer in this contest, became interested in purchasing a multi-wall bag and paper business for sale by Fulton Bag and Cotton Mills Company…