United States Tax Court January 14, 1964, Docket Nos. 91844, 91845, 93682, 93683 (Hrobon v. Commissioner)

OPINION

The question upon the answer to which all issues here involved hinge, is what the parties intended and what was actually accomplished by the transaction between May and Emil evidenced by the agreement of November 9, 1955. In tax matters we must look to substance rather than form alone, Helvering v. Clifford, 309 U.S.