Gates v. Commissioner
United States Board of Tax Appeals
Liquidating dividend received in 1921 on stock which had been owned for more than two years prior thereto and held as an investment held not to be taxable as capital gain under section 206 of the Revenue Act of 1921.
1Opinion of the Court
*1134OPINION.
Trammell :
The only issue in this proceeding is whether a liquidating dividend received in 1922 under the circumstances sot out in the findings of fact is a capital gain under the provisions of section 206 of the Eevenue Act of 1921 and taxable as such under the provisions of that section or whether it is a dividend within the meaning of section 201 and subject to the surtax imposed by section 211 of the Act.
The pertinent provisions of section 201 are:(a) That the term “dividend” when used in this title * * * means any distribution made by a corporation to its shareholders or members,…
2Cited by3 opinions
- Woodard v. CommissionerUnited States Board of Tax Appeals · 1934
- Gates v. CommissionerUnited States Board of Tax Appeals · 1928
- Guild v. CommissionerUnited States Board of Tax Appeals · 1930