Letts v. Commissioner
United States Board of Tax Appeals
1. INCOME - LIQUIDATING DISTRIBUTIONS. - Under section 201(c), Revenue Act of 1926, distributions in liquidation by a corporation, whether made as from surplus or capital, held, chargeable against the cost basis of the stock in the hands of the recipient.
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1. INCOME - LIQUIDATING DISTRIBUTIONS. - Under section 201(c), Revenue Act of 1926, distributions in liquidation by a corporation, whether made as from surplus or capital, held, chargeable against the cost basis of the stock in the hands of the recipient. Holmby Corp.,28 B.T.A. 1092, followed. 2. Id. - Liquidating distributions to a trustee and representing in his hands capital net gain under sections 208(a) and (b) and 219(a) of the Revenue Act of 1926, held, subject to the same provisions in the hands of the beneficiary when distributed to him, although distributable only as dividends on…
1Opinion of the Court
OPINION.
Leech:
This proceeding seeks redetermination of a deficiency of $92,721.18 in income tax determined by respondent for the calendar year 1927.
The respondent confesses error under the following assignments of petitioner: (a) The inclusion of $353,791.74 in ordinary income of petitioner after having included this same amount in computing capital net gain, (b) including in ordinary income $1,756.43 as dividends received and including the same item in computing capital gain, and (c) including $20,491.47 in income subject to normal tax where such income was reported as dividends received.…
2Cases cited5 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Freuler v. HelveringSupreme Court of the United States · 1934
- Holmby Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Anderson v. CommissionerUnited States Board of Tax Appeals · 1934
- Canal Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1934
3Cited by12 opinions
- Estate of Petschek v. CommissionerUnited States Tax Court · 1983
- United States v. Frank N. Mattison and Ida G. MattisonCourt of Appeals for the Ninth Circuit · 1959
- Welch v. SolomonCourt of Appeals for the Ninth Circuit · 1938
- McNaghten v. United StatesUnited States Court of Claims · 1937
- Mattison v. United StatesDistrict Court, D. Idaho · 1958
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