Angelus Bldg. & Inv. Co. v. Commissioner
United States Board of Tax Appeals
Payments to stockholders carried on corporate books as interest held to be dividends.
1Opinion of the Court
*672OPINION.
Van Fossan:
The sole issue in these proceedings is whether the amounts of $31,242.78 and $10,919 paid by the petitioner in the years 1922 and 1923, respectively, represented interest paid on loans or *673dividends paid on capital stock. If the former position is correct, it follows that the recipients of such payments, the J. H. Braly trustees and A. H. Braly, were creditors of the petitioner corporation, and not its stockholders. Consequently, such amounts would be deductible from the gross income of the petitioner.
The petitioner was a close corporation whose stock was originally owned…
2Cases cited2 opinions
- Armstrong v. Union Trust & Savings BankCourt of Appeals for the Ninth Circuit · 1918
- Smith v. Southern Foundry Co.Court of Appeals of Kentucky · 1915
3Cited by7 opinions
- O. P. P. Holding Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
- Colorado Life Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Wentworth v. CommissionerUnited States Tax Court · 1973
- Angelus Bldg. & Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Bakers' Mut. Co-operative Asso. v. CommissionerUnited States Board of Tax Appeals · 1939
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