Kunze v. Commissioner
United States Tax Court
Dividend declared and made payable in 1946 by a corporation of which petitioner and another were stockholders but, at petitioner's request, discriminatorily withheld from his possession until the following year, held constructively received by him in the prior year. Avery v. Commissioner, 292 U.S. 210, distinguished.
1Opinion of the Court
Frank W. Kunze, Petitioner, v. Commissioner of Internal Revenue, Respondent
Kunze v. Commissioner
Docket No. 34073
United States Tax Court
19 T.C. 29; 1952 U.S. Tax Ct. LEXIS 74;
October 13, 1952, Promulgated
Decision will be entered for the respondent.
Dividend declared and made payable in 1946 by a corporation of which petitioner and another were stockholders but, at petitioner's request, discriminatorily withheld from his possession until the following year, held constructively received by him in the prior year. Avery v. Commissioner, 292 U.S. 210, distinguished.
Sidney Gelfand and Bernard Weiss,…
2Cases cited2 opinions
- Avery v. CommissionerSupreme Court of the United States · 1934
- Kunze v. CommissionerUnited States Tax Court · 1952