Frontier Sav. Asso. v. Commissioner
United States Tax Court
In 1978 and 1979, petitioner, a stockholder of the Federal Home Loan Bank of Chicago (the Chicago Bank), received common stock dividends from the Chicago Bank. Also in 1978 and 1979, some of the stockholders requested that a portion of their shares of common stock in the Chicago Bank be redeemed. As it had in prior years, the Chicago Bank redeemed all shares of its common stock it was requested to redeem.
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In 1978 and 1979, petitioner, a stockholder of the Federal Home Loan Bank of Chicago (the Chicago Bank), received common stock dividends from the Chicago Bank. Also in 1978 and 1979, some of the stockholders requested that a portion of their shares of common stock in the Chicago Bank be redeemed. As it had in prior years, the Chicago Bank redeemed all shares of its common stock it was requested to redeem. Held: No stockholder had an election within the meaning of sec. 305(b)(1), I.R.C. 1954, to receive cash dividends in lieu of common stock dividends because the Chicago Bank retained…
1Opinion of the Court
Frontier Savings Association and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent; Frontier Savings and Loan Association, Petitioner v. Commissioner of Internal Revenue, Respondent
Frontier Sav. Asso. v. Commissioner
Docket Nos. 16209-81, 24559-83
United States Tax Court
87 T.C. 665; 1986 U.S. Tax Ct. LEXIS 47; 87 T.C. No. 40;
September 24, 1986, Filed
Decisions will be entered under Rule 155.
In 1978 and 1979, petitioner, a stockholder of the Federal Home Loan Bank of Chicago (the Chicago Bank), received common stock dividends from the Chicago Bank. Also in 1978 and 1979,…
Also in this document: Concurrence.
2Cases cited4 opinions
- Estate of Lang v. CommissionerUnited States Tax Court · 1975
- The Estate of Grace E. Lang, Deceased. Richard E. Lang v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Frontier Sav. Asso. v. CommissionerUnited States Tax Court · 1986
- Rinker v. United StatesDistrict Court, S.D. Florida · 1968