United States Tax Court September 30, 1966, Docket No. 93774 (Haserot v. Commissioner)

lead-opinion

Tannenwald, Judge:

Respondent determined a deficiency in petitioners’1 1958 Federal income tax of $82,224.86. The principal ground for the deficiency was respondent’s claim that cash credited to petitioner, in a transaction involving the transfer of stock for stock and a cash credit, constituted dividend income.