Sweeney was the chairman of Sweeney Inc. a large hardware and lumber store. When Sweeney became ill his son took over the business but sold the property and all of the inventory valued at $2000000 within a year. Shortly thereafter Sweeney recovered and took control of the corporation. The corporation purchased a new building and started a new hardware store. This store although slightly larger than the original store did not carry any lumber. Its inventory was valued at $1900000. Sweeney changed the name of the corporation and the board authorized a plan of partial liquidation. Pursuant to that plan the original shares of the corporation were replaced and Sweeney distributed almost $2000000 to the shareholders as part of the partial liquidation. Each shareholder received $5000 and one share of stock for every two of the old corporation that were owned.