Barbourville Brick Co. v. Commissioner
United States Tax Court
Payment by petitioner corporation to its majority stockholder, the widow of its deceased president, pursuant to corporate resolution adopted after his death, held, on the facts, to be a dividend not deductible by petitioner.
1Opinion of the Court
OPINION.
Offer, Judge:
This proceeding involves a deficiency hi Federal income tax for 1954 in the amount of $1,530. The issue is whether certain payments to the widow of the deceased president of petitioner are deductible under the provisions of section 182(a) or section 404(a),I.R.C. 1954.
All the facts have been stipulated. They are so found and are incorporated herein by this reference.
The Barbourville Brick Company was incorporated under the laws of the Commonwealth of Kentucky in 1936 for the purpose of producing structural clay products and selling all of the clay it mined in the form of…
2Cases cited12 opinions
- Helvering v. WoodSupreme Court of the United States · 1940
- Paramount-Richards Theatres, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- United Mercantile Agencies, Inc. v. CommissionerUnited States Tax Court · 1955
- Ruth T. Lengsfield, Coralie Mayer Lengsfield and Blanche L. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- F. W. Drybrough v. Commissioner of Internal Revenue, L. N. Simpson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
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3Cited by33 opinions
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- Primo Pants Co. v. CommissionerUnited States Tax Court · 1982
- Kuper v. CommissionerUnited States Tax Court · 1974
- Interstate Drop Forge Company, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- Evans v. CommissionerUnited States Tax Court · 1962
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