Legal Opinion

Pacific Southwest Realty Co. v. Commissioner

United States Board of Tax Appeals

Decided October 24, 1941No. Docket No. 102605Published

1. In conformity with its articles of incorporation petitioner issued and sold two series of "Cumulative Preferred Serial Stock." The certificates stated that they were redeemable at par, plus all unpaid, accrued, or accumulated dividends, and that the holders should have the right to enforce payment the same as on any unconditional claim or debt against the corporation.

Read the full summary

1. In conformity with its articles of incorporation petitioner issued and sold two series of "Cumulative Preferred Serial Stock." The certificates stated that they were redeemable at par, plus all unpaid, accrued, or accumulated dividends, and that the holders should have the right to enforce payment the same as on any unconditional claim or debt against the corporation. The articles also authorized the corporation to issue bonds, though the total indebtedness of the corporation could not exceed 50 percent of the appraised value of the property subject thereto. First mortgage bonds in an…

1Opinion of the Court

PACIFIC SOUTHWEST REALTY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Pacific Southwest Realty Co. v. Commissioner

Docket No. 102605.

United States Board of Tax Appeals

45 B.T.A. 426; 1941 BTA LEXIS 1115;

October 24, 1941, Promulgated

1. In conformity with its articles of incorporation petitioner issued and sold two series of "Cumulative Preferred Serial Stock." The certificates stated that they were redeemable at par, plus all unpaid, accrued, or accumulated dividends, and that the holders should have the right to enforce payment the same as on any unconditional claim or…

2Cases cited16 opinions

  1. John Hancock Mut. Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  2. California Sanitary Co. v. CommissionerUnited States Board of Tax Appeals · 1935
  3. Meridian & T. Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1941
  4. Richmond, Fredericksburg & Potomac R.R. v. CommissionerUnited States Board of Tax Appeals · 1936
  5. O. P. P. Holding Corp. v. CommissionerUnited States Board of Tax Appeals · 1934

11 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API