Wheeler v. Commissioner
United States Tax Court
In December 1936, the W corporation declared certain dividends payable on December 31, 1936. The resolution making the declaration authorized the management of the company to borrow from any or all stockholders any or all of the "dividends so paid."
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In December 1936, the W corporation declared certain dividends payable on December 31, 1936. The resolution making the declaration authorized the management of the company to borrow from any or all stockholders any or all of the "dividends so paid." In January 1937 the dividends were charged to surplus and credited to the dividends payable account as of December 31, 1936. Shortly after the close of the year notes were issued as of the last day of the year to stockholders in the amount of the dividends to which each was entitled. Held, as the dividends declared in December 1936 were not "paid…
1Opinion of the Court
Estate of John H. Wheeler, Deceased, Elliott H. Wheeler and Rollo C. Wheeler, Executors, Petitioners, et al., 1 Commissioner of Internal Revenue, Respondent
Wheeler v. Commissioner
Docket Nos. 107256, 107257, 107259, 107261, 107262, 107264
United States Tax Court
1 T.C. 401; 1943 U.S. Tax Ct. LEXIS 260;
January 5, 1943, Promulgated
Decisions will be entered for the respondent.
In December 1936, the W corporation declared certain dividends payable on December 31, 1936. The resolution making the declaration authorized the management of the company to borrow from any or all stockholders any or all of…
2Cases cited1 opinion
- Wheeler v. CommissionerUnited States Tax Court · 1943