Paper v. Commissioner
United States Board of Tax Appeals
Pursuant to an election given to stockholders in a resolution declaring corporate dividends, the petitioners elected to receive, and were paid, in corporation's preferred stock for their shares in the corporate earnings distributed. Held, in the circumstances shown, that the petitioners are taxable upon the stock they received as an ordinary corporate dividend.
1Opinion of the Court
*524OPINION.
Lansdon :
These petitioners have appealed from the respondent’s determinations of their income taxes for the year 1929. Each also asks affirmative relief in the way of refunds for alleged overpay-ments of taxes in the year reviewed. The items in dispute are, in Docket No. 59040, taxes, $677.52, and refund claims, $161.60; in Docket No. 64749, taxes, $168.75, and refund claim, $32.75.
The sole issue is whether or not the respondent committed error in holding the petitioners taxable for dividends paid in the stock of a family corporation known as Paper, Calmenson & Co., hereinafter…
2Cases cited8 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Towne v. EisnerSupreme Court of the United States · 1918
- Gibbons v. MahonSupreme Court of the United States · 1890
- United States v. MellonCourt of Appeals for the Third Circuit · 1922
- Logan County v. United StatesSupreme Court of the United States · 1898
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3Cited by2 opinions
- Wood v. CommissionerUnited States Board of Tax Appeals · 1934
- Paper v. CommissionerUnited States Board of Tax Appeals · 1933