Legal Opinion

Finance & Investment Corp. v. Burnet

Court of Appeals for the D.C. Circuit

Decided March 7, 1932No. 5346PublishedCited by 9 opinions

1Opinion of the Court

MARTIN, Chief Justice.

This appeal relates to corporation income taxes for the year. 1925. Appellant, a Delaware corporation, claimed certain deductions in its returns for that year for payments made during the year to its preferred stockholders, claiming that the holders of the preferred stock had thereby become creditors of the corporation, and that the payments, although called dividends, were in fact interest. The Commissioner, however, held that the payments were dividends and not interest, and therefore disallowed the deductions. A corresponding deficiency was then asserted in the…

2Cases cited5 opinions

  1. Warren v. KingSupreme Court of the United States · 1883
  2. Arthur R. Jones Syndicate v. Commissioner of I. RevenueCourt of Appeals for the Seventh Circuit · 1927
  3. Armstrong v. Union Trust & Savings BankCourt of Appeals for the Ninth Circuit · 1918
  4. Scott v. Baltimore & Ohio RailroadCourt of Appeals of Maryland · 1901
  5. Doak v. RunyanMichigan Supreme Court · 1875

3Cited by9 opinions

  1. Commissioner of Int. Rev. v. Meridian & Thirteenth R. Co.Court of Appeals for the Seventh Circuit · 1942
  2. United States v. Title Guarantee & Trust Co.Court of Appeals for the Sixth Circuit · 1943
  3. United States v. South Georgia Ry. Co.Court of Appeals for the Fifth Circuit · 1939
  4. Haffenreffer Brewing Co. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1940
  5. First Mortgage Corp. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1943

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