Sherwin v. Commissioner
United States Board of Tax Appeals
On December 20, 1937, the Mid-Continent Securities Co., a personal holding company, sold to its principal shareholders shares of stock held by it as investments at a large profit, the purchasers paying a small amount down on their contract and agreeing to pay the balance on or before December 1, 1942, with interest at 4 percent per annum. Thereafter, the purchasers received the dividends upon the shares acquired and paid interest to the seller upon their obligations.
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On December 20, 1937, the Mid-Continent Securities Co., a personal holding company, sold to its principal shareholders shares of stock held by it as investments at a large profit, the purchasers paying a small amount down on their contract and agreeing to pay the balance on or before December 1, 1942, with interest at 4 percent per annum. Thereafter, the purchasers received the dividends upon the shares acquired and paid interest to the seller upon their obligations. The respondent has determined that the sales made by the company to its shareholders may not be "recognized for income tax…
1Opinion of the Court
JOHN SHERWIN, PETITIONER, v. commissioner of internal REVENUE, RESPONDENT.
THE MID-CONTINENT SECURITIES COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
FRANCIS M. SHERWIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Sherwin v. Commissioner
Docket Nos. 106728-106730.
United States Board of Tax Appeals
46 B.T.A. 330; 1942 BTA LEXIS 876;
February 18, 1942, Promulgated
On December 20, 1937, the Mid-Continent Securities Co., a personal holding company, sold to its principal shareholders shares of stock held by it as investments at a large profit, the purchasers…
2Cases cited1 opinion
- Sherwin v. CommissionerUnited States Board of Tax Appeals · 1942