12 B.T.A. 974 | B.T.A. | 1928
Lead Opinion
The respondent does not contend in this case that capital was a material income-producing factor. It is our opinion that C. J. Swift must be regarded as the actual owner of all the stock of the petitioner in 1920 and 1921. Although the stock record book of the corporation shows stock outstanding in the names of persons other than Swift during those years, the certificates for. all but 20 per cent of the stock were immediately after issue indorsed in blank and handed to Swift, who thereafter kept them in
Reviewed by the Board.
Judgment will he entered for the ‘petitioner.