Hancock County Federal Savings & Loan Ass'n v. Commissioner

OPINION.

HaRRon, Judge:

Respondent, under section 23(r) (1), 1939 Code,1 allowed petitioner a deduction in 1952 for its December 31, 1952, dividends of $105,301.64, but he disallowed a deduction in 1952 for the December 31, 1951, dividends of $71,799.91. The first question is whether all or part of the December 31, 1951, dividends were not withdrawable on demand, subject only to customary notice to withdraw, prior to January 2, 1952. If this question is decided for petitioner, respondent, in the alternative, contends that the December 31,1952, dividends were not withdrawable on demand before…