Trianon Hotel Co. v. Commissioner
United States Board of Tax Appeals
1. The "aggregate of the amounts which can be distributed within the taxable year as dividends without violating a provision of a written contract executed by the corporation prior to May 1, 1936" includes undivided profits on hand at the beginning of the taxable year and the current net earnings of that year. 2. Where the amount of a corporation's adjusted net income for the taxable year does not exceed the aggregate of the amounts which can be distributed as dividends…
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1. The "aggregate of the amounts which can be distributed within the taxable year as dividends without violating a provision of a written contract executed by the corporation prior to May 1, 1936" includes undivided profits on hand at the beginning of the taxable year and the current net earnings of that year. 2. Where the amount of a corporation's adjusted net income for the taxable year does not exceed the aggregate of the amounts which can be distributed as dividends without violating the provision of a written contract executed prior to May 1, 1936, it is not entitled to a credit under…
1Opinion of the Court
TRIANON HOTEL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Trianon Hotel Co. v. Commissioner
Docket No. 95972.
United States Board of Tax Appeals
44 B.T.A. 1073; 1941 BTA LEXIS 1235;
July 22, 1941, Promulgated
1. The "aggregate of the amounts which can be distributed within the taxable year as dividends without violating a provision of a written contract executed by the corporation prior to May 1, 1936" includes undivided profits on hand at the beginning of the taxable year and the current net earnings of that year.
2. Where the amount of a corporation's adjusted net income…
2Cases cited1 opinion
- Trianon Hotel Co. v. CommissionerUnited States Board of Tax Appeals · 1941