Harkness v. Commissioner
United States Board of Tax Appeals
1. The amount allowable as a deduction on account of charitable contributions under section 23(n) of the Revenue Act of 1928 is to be computed upon the entire net income without excluding capital net gains. Helvering v. Bliss,293 U.S. 144. 2. Dividends declared and payable in 1929 but not received by the petitioner stockholder until 1930 are taxable in the year of actual receipt where the petitioner made his returns on the cash receipts and disbursements basis.
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1. The amount allowable as a deduction on account of charitable contributions under section 23(n) of the Revenue Act of 1928 is to be computed upon the entire net income without excluding capital net gains. Helvering v. Bliss,293 U.S. 144. 2. Dividends declared and payable in 1929 but not received by the petitioner stockholder until 1930 are taxable in the year of actual receipt where the petitioner made his returns on the cash receipts and disbursements basis. Avery v. Commissioner,292 U.S. 210. 3. Rights to subscribe for convertible debenture bonds issued by a corporation to its…
1Opinion of the Court
EDWARD S. HARKNESS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
MARY S. HARKNESS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Harkness v. Commissioner
Docket Nos. 65169, 71310, 71311.
United States Board of Tax Appeals
31 B.T.A. 1100; 1935 BTA LEXIS 1022;
January 22, 1935, Promulgated
1. The amount allowable as a deduction on account of charitable contributions under section 23(n) of the Revenue Act of 1928 is to be computed upon the entire net income without excluding capital net gains. Helvering v. Bliss,293 U.S. 144.
2. Dividends declared and payable in 1929 but…
2Cases cited14 opinions
- Helvering v. BlissSupreme Court of the United States · 1934
- Avery v. CommissionerSupreme Court of the United States · 1934
- United States v. WoodwardSupreme Court of the United States · 1921
- Powel v. CommissionerUnited States Board of Tax Appeals · 1932
- Leach v. CommissionerUnited States Board of Tax Appeals · 1929
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