Edison Sec. Corp. v. Commissioner
United States Board of Tax Appeals
1. Distributions made by a corporation not in excess of earnings held under the circumstances to be ordinary and not liquidating dividends, no dissolution or winding up having at that time been decided upon or definitely planned, and notwithstanding the fact that liquidation had been suggested as a means of resolving a dispute between shareholders, and the fact that a later determination to liquidate and dissolve was carried out. 2. The statutory definition of reorganization…
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1. Distributions made by a corporation not in excess of earnings held under the circumstances to be ordinary and not liquidating dividends, no dissolution or winding up having at that time been decided upon or definitely planned, and notwithstanding the fact that liquidation had been suggested as a means of resolving a dispute between shareholders, and the fact that a later determination to liquidate and dissolve was carried out. 2. The statutory definition of reorganization is applicable to the events and occurrences therein described and does not embrace mere intends, plans or executory…
1Opinion of the Court
EDISON SECURITIES CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Edison Sec. Corp. v. Commissioner
Docket No. 52662.
United States Board of Tax Appeals
29 B.T.A. 483; 1933 BTA LEXIS 933;
December 5, 1933, Promulgated
1. Distributions made by a corporation not in excess of earnings held under the circumstances to be ordinary and not liquidating dividends, no dissolution or winding up having at that time been decided upon or definitely planned, and notwithstanding the fact that liquidation had been suggested as a means of resolving a dispute between shareholders, and the…
2Cases cited6 opinions
- United States v. PhellisSupreme Court of the United States · 1921
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Edison Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Simms v. CommissionerUnited States Board of Tax Appeals · 1933
- Green v. CommissionerUnited States Board of Tax Appeals · 1931
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