United States Tax Court April 23, 1957, Docket Nos. 47893, 54352, 54396 (Consolidated Premium Iron Ores Ltd. v. Commissioner)

OPINION.

Van Fossan, Judge:

It is at once evident on the statement of the issues in these cases that respondent has taken two utterly inconsistent positions in his determinations. If Premium was liable for taxes on the bargain purchase of 1,437,500 shares of Steep Rock stock at 1 cent per share, as respondent originally held, the individual petitioners cannot also be liable — and vice versa.