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
SWIFT, Judge:
In statutory notices of deficiency dated June 3, 1981, and August 12, 1983, respondent determined deficiencies in petitioner’s Federal income tax liabilities as follows:
Years Deficiencies
1977 . $1,628.15
1978 . 19,376.14
1979 . 17,887.00
These cases have been consolidated for purposes of trial, briefing, and opinion.
Following concessions, the issue remaining for decision is whether stock dividends received by petitioner in 1978 and 1979 from the Federal Home Loan Bank of Chicago are taxable to petitioner under section 305(b)(1)1. The resolution of this issue will affect the…
2Cases cited3 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
- Rinker v. United StatesDistrict Court, S.D. Florida · 1968
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- Beyer v. CommissionerUnited States Tax Court · 1989
- Colonial Savings Ass'n v. CommissionerCourt of Appeals for the Seventh Circuit · 1988
- Colonial Savings Association and Subsidiaries, Cross v. Commissioner of Internal Revenue, Cross-Appellant. Frontier Savings and Loan Association v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
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