United States Tax Court April 3, 1959, Docket Nos. 62747, 64407 (Alvord v. Commissioner)

lead-opinion

OPINION.

Black, Judge:

The question involved in these proceedings is whether the Commissioner was correct in including 95 per cent of the undistributed Supplement P net income of Hekor, a Canadian corporation, for the years 1951, 1953, and 1954,2 in the gross income of petitioner, a United States citizen, for those years.