R. J. Reynolds Tobacco Co. v. Commissioner
United States Tax Court
During 1949 and 1950 petitioner made distributions under its by-law providing therefor to the extent of a certain percentage of annual profits over a specified base. The distributions were made to certain of its employees and to several employees of its wholly-owned subsidiary entitled to participate on the basis of and in proportion to their respective holdings of petitioner's A stock.
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During 1949 and 1950 petitioner made distributions under its by-law providing therefor to the extent of a certain percentage of annual profits over a specified base. The distributions were made to certain of its employees and to several employees of its wholly-owned subsidiary entitled to participate on the basis of and in proportion to their respective holdings of petitioner's A stock. Respondent disallowed deduction therefor on the ground that such distributions were in reality preferential dividends. Held, that the distributions to petitioner's own employees were made in accordance with an…
1Opinion of the Court
R. J. Reynolds Tobacco Company v. Commissioner.
R. J. Reynolds Tobacco Co. v. Commissioner
Docket No. 45432.
United States Tax Court
T.C. Memo 1956-161; 1956 Tax Ct. Memo LEXIS 132; 15 T.C.M. (CCH) 810; T.C.M. (RIA) 56161;
June 6, 1956
During 1949 and 1950 petitioner made distributions under its by-law providing therefor to the extent of a certain percentage of annual profits over a specified base. The distributions were made to certain of its employees and to several employees of its wholly-owned subsidiary entitled to participate on the basis of and in proportion to their respective holdings of…
2Cases cited19 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. LoBueSupreme Court of the United States · 1956
- United States v. American Tobacco Co.Supreme Court of the United States · 1910
- L. Schepp Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- United States v. Joliet & Chicago RailroadSupreme Court of the United States · 1942
14 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Bianchi v. CommissionerUnited States Tax Court · 1976
- Texasgulf, Inc. v. CommissionerUnited States Tax Court · 1976
- Bianchi v. CommissionerUnited States Tax Court · 1976