United States Board of Tax Appeals March 21, 1941, Docket Nos. 99651, 99875, 99937. (Levit v. Commissioner)

lead-opinion

*1083OPINION.

Opper :

It has been frequently asserted that solution of the question presented here — whether a distribution in partial liquidation is such in time and manner as in substance to approximate a dividend — must rest upon the particular facts of each individual case. E. M. Peet, 43 B. T. A. 852.