Wall Products, Inc. v. Commissioner , 11 T.C. 51 ( 1948 )

Turnee, J.,

dissenting: In my opinion the facts in this case are not such as to justify the conclusion that petitioner’s two stockholders, Strange and Kastner, were the owners of a secret formula used by petitioner which would supply a basis for the deduction under section 23 (a) (1) (A) of the Internal Revenue Code of amounts paid to them by petitioner as payments for use of a secret formula. In my judgment the payments in question were nothing more than a distribution by petitioner of corporate profits to its principal stockholders.