Soanes

The individual petitioners are directors of petitioner Vallejo Bus Company, a California corporation dissolved on December 31, 1942, and are hereafter described as the Corporation. It sought in the Tax Court a *748 redetermination of its 1942 income and declared value excess profits tax as assessed by the respondent. The amount of the assessment, if valid against the Corporation, is not questioned. Particularly, the petition for redetermination concerns the taxes assessed on income earned between June 1, 1942, and September 15, 1942.

The Corporation contended before the Tax Court that on June 1, 1942, it had transferred all its assets to the partnership of the three individual petitioners and that it had no earnings after that date and that whatever was earned between June 1 and September 15 was income to the partnership as of right or at least under claim of right.

The Tax Court found that there was no transfer by the Corporation until after September 15, 1942, and that what was •done by the copartners between the two dates was performed by the Corporation through them as its agents acting for it and not in their own right or under a claim of right.

The Corporation contends…