H. B. Snively v. Commissioner of Internal Revenue

TUTTLE, Circuit Judge.

The question here for decision is whether the Tax Court erred in holding that citrus fruit harvested from a grove owned by a corporation which it had been determined should be liquidated, and with respect to which a petition to the appropriate state court for dissolution had been filed, but which remained in existence for several months following the sale resulted in income to the corporation or to the sole stockholder who had directed that the sales be made for his personal account, and where, on final liquidation, not only the crops but also the entire assets of the…