Legal Opinion

Darrow v. Commissioner

United States Board of Tax Appeals

Decided September 22, 1927No. Docket No. 929Published

The term "dividends" as defined in section 201 of the Revenue Act of 1921, includes distributions in liquidation of a corporation to the extent of the earnings or profits accumulated since February 28, 1913, contained therein, and to the extent of those earnings such distributions are taxable as dividends, subject to the surtax and exempt from the normal tax.

1Opinion of the Court

FRANK D. DARROW, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Darrow v. Commissioner

Docket No. 929.

United States Board of Tax Appeals

8 B.T.A. 276; 1927 BTA LEXIS 2934;

September 22, 1927, Promulgated

The term "dividends" as defined in section 201 of the Revenue Act of 1921, includes distributions in liquidation of a corporation to the extent of the earnings or profits accumulated since February 28, 1913, contained therein, and to the extent of those earnings such distributions are taxable as dividends, subject to the surtax and exempt from the normal tax.

Wilbur F. Denious, Esq.,…

2Cases cited13 opinions

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. Lynch v. HornbySupreme Court of the United States · 1918
  3. Lynch v. TurrishSupreme Court of the United States · 1918
  4. Edwards v. DouglasSupreme Court of the United States · 1925
  5. Greenwood v. CommissionerUnited States Board of Tax Appeals · 1925

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