Stephen F. Heringer, Mabel H. Heringer, John F. Heringer, and Alta G. Heringer v. Commissioner of Internal Revenue

ORR, Circuit Judge.

John F. and Stephen Heringer and their wives Mabel H. and Alta G. respectively, and hereafter petitioners, ap-. pear from the record to be thrifty people who have conducted successful farming operations during the years. Each couple has several children. On or about January 5, 1947 petitioners concluded that the major portion of their property should be transferred to a corporation, whose stock was to be distributed between parents and children. Pursuant thereto they caused to be incorporated Vorden Farms, Inc.i hereafter the corporation. The corporation issued 50;000…