Continental Nat'l Bank & Trust Co. v. Commissioner
United States Board of Tax Appeals
The decedent received dividends on January 15, April 15, July 15, and October 15, 1922, from a corporation which on January 1, 1921, had no undistributed earnings or profits accumulated since February 28, 1913, and which corporation sustained a loss of $896,168.23 for the first six months of 1921, realized a profit of $346,724.17 for the last six months of 1921, sustained a loss of $141,175.74 for the first six months of 1922, and realized a profit of $390,365.92 for the…
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The decedent received dividends on January 15, April 15, July 15, and October 15, 1922, from a corporation which on January 1, 1921, had no undistributed earnings or profits accumulated since February 28, 1913, and which corporation sustained a loss of $896,168.23 for the first six months of 1921, realized a profit of $346,724.17 for the last six months of 1921, sustained a loss of $141,175.74 for the first six months of 1922, and realized a profit of $390,365.92 for the last six months of 1922. Held that in determining whether the dividends paid in 1922 were paid from earnings or profits…
1Opinion of the Court
*832OPINION.
Matthews :
The question here presented is what portion of the $52,-185 received by the decedent during 1922 as dividends from Wilson Bros., Inc., should be included in the decedent’s gross income under section 213 of the Revenue Act of 1921, which section includes in the term “ gross income ” among other things the item of “ dividends.” Section 201 of the same Act reads in part as follows:
Sec. 201 .(a) That the term “dividend” when used in this title * * * means any distribution made by a corporation to its shareholders or members * * * out of its earnings or profits accumulated since…
2Cases cited2 opinions
- Edwards v. DouglasSupreme Court of the United States · 1925
- Mason v. RoutzahnSupreme Court of the United States · 1927
3Cited by3 opinions
- Albert Lea Packing Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Continental Nat'l Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Elmhirst v. CommissionerUnited States Board of Tax Appeals · 1940