Legal Opinion

Roddy v. Commissioner

United States Board of Tax Appeals

Decided March 6, 1934No. Docket Nos. 71403, 71405PublishedCited by 1 opinion

Dividends distributed pursuant to informal action of directors on December 31, 1930, the checks representing the same being received by petitioners as stockholders on January 2, 1931, are taxable in 1930.

1Opinion of the Court

*7OPINION.

Teammell :

The petitioner takes the position that the facts in this case distinguish it from that line of cases which hold that the dividends declared on December 31 of one year and the checks then mailed but not received by the stockholder until the following year constitute taxable income in the year of distribution instead of in the year of receipt. See Effie B. Shearman, 26 B.T.A. 716; affirmed by the Circuit Court of Appeals for the Second Circuit, 66 Fed. (2d) 256; Franklin J. Matchette, 26 B.T.A. 909; Mary Miller Braxton, 22 B.T.A. 128. The petitioner does not attack the…

2Cases cited1 opinion

  1. Braxton v. CommissionerUnited States Board of Tax Appeals · 1931

3Cited by1 opinion

  1. Roddy v. CommissionerUnited States Board of Tax Appeals · 1934

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

Powered by the Exa API