Legal Opinion

Signal Oil Co. v. Commissioner

United States Tax Court

Decided June 11, 1943No. Docket No. 107813Published

1. The extension by mutual agreement on July 30, 1936, of a two-year contract executed on July 31, 1934, which contract bound petitioner to refrain from dividend payments during its term but contained no provision for its extension or renewal, held to constitute a new contract, rather than a mere continuation of the old, so that petitioner is not entitled to credits by reason of a contract executed prior to May 1, 1936, restricting the payment of dividends. 2. Credit allowed…

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1. The extension by mutual agreement on July 30, 1936, of a two-year contract executed on July 31, 1934, which contract bound petitioner to refrain from dividend payments during its term but contained no provision for its extension or renewal, held to constitute a new contract, rather than a mere continuation of the old, so that petitioner is not entitled to credits by reason of a contract executed prior to May 1, 1936, restricting the payment of dividends. 2. Credit allowed by reason of a deficit which prevented petitioner under state law from declaring dividends. Sec. 501 (a) (2), Revenue…

1Opinion of the Court

Signal Oil Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Signal Oil Co. v. Commissioner

Docket No. 107813

United States Tax Court

2 T.C. 90; 1943 U.S. Tax Ct. LEXIS 141;

June 11, 1943, Promulgated

Decision will be entered under Rule 50.

1. The extension by mutual agreement on July 30, 1936, of a two-year contract executed on July 31, 1934, which contract bound petitioner to refrain from dividend payments during its term but contained no provision for its extension or renewal, held to constitute a new contract, rather than a mere continuation of the old, so that petitioner is…

2Cases cited1 opinion

  1. Signal Oil Co. v. CommissionerUnited States Tax Court · 1943

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