Werner Abegg v. Commissioner of Internal Revenue, Cresta Corporation, S.A., Transferee v. Commissioner of Intenal Revenue

FRIENDLY, Circuit Judge:

These two appeals from a decision of the Tax Court, 50 T.C. 145, one by the taxpayer and the other by the Commissioner, concern a series of transactions in which Werner Abegg, a Swiss citizen, liquidated one wholly-owned personal holding company and transferred all its assets, plus other securities in substantial amount, to another personal holding company. Although the appeals relate to different tax years and present independent legal issues, there is a sufficient identity in the dramatis personae to make it convenient to state all the facts at the outset.

I. The Facts