Spreckels v. Commissioner
United States Tax Court
1. Dividends. -- The extent to which distributions received by petitioners as stockholders of the J. D. & A. B. Spreckels Co. during 1938, 1939, and 1940 constituted taxable dividends is by stipulation to be determined pursuant to the opinion in Grace H. Kelham, 13 T. C. 984. 2. Id. -- Where under section 186, Revenue Act of 1942, a personal holding company filed a claim for relief from personal holding company surtax on account of a distribution to its sole stockholder,…
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1. Dividends. -- The extent to which distributions received by petitioners as stockholders of the J. D. & A. B. Spreckels Co. during 1938, 1939, and 1940 constituted taxable dividends is by stipulation to be determined pursuant to the opinion in Grace H. Kelham, 13 T. C. 984. 2. Id. -- Where under section 186, Revenue Act of 1942, a personal holding company filed a claim for relief from personal holding company surtax on account of a distribution to its sole stockholder, accompanied by the stockholder's consent to the inclusion of the full amount of such distribution in her gross income as a…
1Opinion of the Court
OPINION.
Tyson, Judge:
These consolidated proceedings involve income tax deficiencies determined by respondent against each petitioner, respectively, for the years and in the amounts, as follows:
Petitioner Docket No. 1933 1940
Adolph B. Spreckels___ 6628 $465.91 $2,843.10 $65,270.85
Dorothy O. Spreckels.— 6629 221.25 68,235.70
John N. Rosekrans and Alma Spreckels Rosekrans.. 6678 2,781.22 4,930.18 24,832.76
Spreckels-Rosekrans Investment Co. 6677 21.81 464.64
The proceeding of Spreckels-Rosekrans Investment Co., Docket No. 5677, also involves personal holding company surtax deficiencies of $555.73…
2Cases cited1 opinion
- Kelham v. CommissionerUnited States Tax Court · 1949
3Cited by1 opinion
- Spreckels v. CommissionerUnited States Tax Court · 1949