United States Tax Court December 4, 1952, Docket Nos. 34209, 34210 (Heiderich v. Commissioner)

lead-opinion

OPINION.

Hill, Judge:

Only one issue is before us and it involves the question whether there has been incurred an ordinary or a capital loss where persons who had received distributions on liquidation of a corporation (capital gains) in a later year were required to satisfy a liability of the corporation as transferees of its assets.