Legal Opinion

Connelly v. Commissioner

United States Board of Tax Appeals

Decided April 10, 1934No. Docket Nos. 44081-44083, 44089, 44090, 45745, 45746, 45833, 45834, 46267, 48120, 48121, 48143, 51967, 54713, 54714, 60566, 60745, 60746, 66948Published

1. Held, that rights to subscribe to bonds of the American Telephone & Telegraph Co. issued to stockholders of that company are not income.

Read the full summary

1. Held, that rights to subscribe to bonds of the American Telephone & Telegraph Co. issued to stockholders of that company are not income. T. I. Hare Powel,27 B.T.A. 55. 2. The cancellation and retirement of preferred stock owned by the petitioners in the taxable years held not to have been made under circumstances essentially equivalent to the distribution of taxable dividends so as to make the amounts distributed taxable as dividends under the provisions of section 115(g) of the Revenue Act of 1928.

1Opinion of the Court

JAMES A. CONNELLY, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Connelly v. Commissioner

Docket Nos. 44081-44083, 44089, 44090, 45745, 45746, 45833, 45834, 46267, 48120, 48121, 48143, 51967, 54713, 54714, 60566, 60745, 60746, 66948.

United States Board of Tax Appeals

30 B.T.A. 331; 1934 BTA LEXIS 1341;

April 10, 1934, Promulgated

1. Held, that rights to subscribe to bonds of the American Telephone & Telegraph Co. issued to stockholders of that company are not income. T. I. Hare Powel,27 B.T.A. 55.

2. The cancellation and retirement of preferred stock owned by the petitioners…

2Cases cited2 opinions

  1. Powel v. CommissionerUnited States Board of Tax Appeals · 1932
  2. Connelly v. CommissionerUnited States Board of Tax Appeals · 1934

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API