Legal Opinion

Mackay v. Commissioner

United States Board of Tax Appeals

Decided February 13, 1934No. Docket Nos. 56914-56916Published

A corporation agreed to sell two separate groups of assets theretofore used in its manufacturing business at a price fixed for each group and thereafter declared a dividend in kind, payable by transferring one of such groups to its stockholders. Held, that the stockholders received the agreed purchase price for such assets and not the book value thereof as a taxable dividend.

1Opinion of the Court

HATTIE W. MACKAY, EXECUTRIX, ESTATE OF WALTER S. MACKAY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

SHIRLAW W. MACKAY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

HATTIE W. MACKAY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Mackay v. Commissioner

Docket Nos. 56914-56916.

United States Board of Tax Appeals

29 B.T.A. 1090; 1934 BTA LEXIS 1431;

February 13, 1934, Promulgated

A corporation agreed to sell two separate groups of assets theretofore used in its manufacturing business at a price fixed for each group and thereafter declared a dividend in…

2Cases cited1 opinion

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

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