Blueberry Land Company, Inc. And Richmond Hill Land Company, Inc. v. Commissioner of Internal Revenue

JOHN R. BROWN, Circuit Judge:

The corporate Taxpayers appeal an adverse judgment after trial in the Tax Court. 1 The tax problem arises out of the disposition of certain installment obligations to First Federal. 2 Ostensibly the disposition was made by an intermediate corporation, which had first purchased all of Taxpayers’ stock, and then liquidated Taxpayers to obtain their assets. In substance, says the Government, the disposition was in fact a sale by the corporate Taxpayers, thus subjecting them to tax on the gain arising therefrom under Int. Rev. Code of 1954 § 453(d), 26 U.S.C.A. §…