United States Board of Tax Appeals January 12, 1928, Docket No. 5753 (Underwriter Printing & Publishing Co. v. Commissioner)

*1193OPINION.

Morris :

While all of the facts and circumstances surrounding the issuance of the stock in question by the petitioner tend to establish that the publications alleged to have been turned over to the petitioner for that stock were developed by Mack in his capacity as president of the petitioner and were at all times its property, we are not compelled to consider that question in view