United States Tax Court April 21, 1969, Docket No. 4778-64 (Cardinal Corp. v. Commissioner)

OPINION

Issue 1. Whether $1¡02,521¡..71 Received in the Year 1958 is Gross Income to Petitioner or is it Money Received in Exchcmge for Stock of Petitioner TJnder Section 1082

The first issue to be considered is whether petitioner must include in gross income for 1958 the $402,524.71 received from preferred shareholders and their assignees.