Hirs v. United States

DANIEL HOLCOMBE THOMAS, District Judge.

1. These are consolidated suits for refunds of income taxes. They involve the character and treatment to be accorded payments made the plaintiffs in Case 3236-64 by Forlands, Inc., a corporate taxpayer now dissolved. Its trus*911tees in liquidation and the assigneeowner of its assets, sue in Case 3237-64. The corporate case involves the same payments made to Mr. and Mrs. Hirs in the companion suit. The reciprocal tax effects of the payments present a common question. Were certain advances made to Forlands, Inc., by Mr. and Mrs. Hirs, contributions to capital…