Legal Opinion

Wayne County & Home Sav. Bank v. Commissioner

United States Board of Tax Appeals

Decided July 29, 1932No. Docket No. 49144PublishedCited by 1 opinion

In the taxable years petitioner credited the checking accounts of its stockholders with sums for the payment of taxes assessed against their stock of petitioner. The taxes were paid by the shareholders, none of whom have ever reimbursed petitioner for any part of the sums credited to their accounts.

Read the full summary

In the taxable years petitioner credited the checking accounts of its stockholders with sums for the payment of taxes assessed against their stock of petitioner. The taxes were paid by the shareholders, none of whom have ever reimbursed petitioner for any part of the sums credited to their accounts. Held that so much of the taxes paid each year by each stockholder as was not in excess of the sum credited to his account for that purpose by petitioner is deductible from petitioner's gross income in the year of payment by the stockholder under the provisions of section 234(a)(3) of the Revenue…

1Opinion of the Court

*762OPINION.

Aeundell:

Under the provisions of the revenue act the petitioner is entitled to deduct from its gross income taxes imposed upon the stock of its shareholders which are paid by it without reimbursement from its stockholders. Sec. 284 (a) (8), Eevenue Act of 1926.

The laws of Michigan provide for the assessment of personal taxes on shares of bank stock “ to their owners ” in the township, village *763or city where the bank is located, “ Provided, that the shares owned by a person residing in the county where the bank or trust, deposit or security company is located shall be assessed in the…

2Cases cited2 opinions

  1. Eyke v. LangeMichigan Supreme Court · 1895
  2. City of Muskegon v. LangeMichigan Supreme Court · 1895

3Cited by1 opinion

  1. Wayne County & Home Sav. Bank v. CommissionerUnited States Board of Tax Appeals · 1932

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

Powered by the Exa API