Holmby Corp. v. Commissioner
United States Board of Tax Appeals
1. DIVIDENDS - ORDINARY OR LIQUIDATING DIVIDENDS. - Where petitioner, a holding corporation, owned practically all the stock of another corporation, and such other corporation granted an option for the sale of its department store business, assets (with certain exceptions), good will and corporate name, which option was exercised on October 29, 1926, and thereafter on November 10, 1926, the corporation declared a distribution of $50 per share, and on November 17, 1926,…
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1. DIVIDENDS - ORDINARY OR LIQUIDATING DIVIDENDS. - Where petitioner, a holding corporation, owned practically all the stock of another corporation, and such other corporation granted an option for the sale of its department store business, assets (with certain exceptions), good will and corporate name, which option was exercised on October 29, 1926, and thereafter on November 10, 1926, the corporation declared a distribution of $50 per share, and on November 17, 1926, declared another distribution of all surplus profits on hand on November 19, 1926, and was disincorporated on or about…
1Opinion of the Court
HOLMBY CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Holmby Corp. v. Commissioner
Docket No. 51303.
United States Board of Tax Appeals
28 B.T.A. 1092; 1933 BTA LEXIS 1051;
August 15, 1933, Promulgated
1. DIVIDENDS - ORDINARY OR LIQUIDATING DIVIDENDS. - Where petitioner, a holding corporation, owned practically all the stock of another corporation, and such other corporation granted an option for the sale of its department store business, assets (with certain exceptions), good will and corporate name, which option was exercised on October 29, 1926, and thereafter on…
2Cases cited18 opinions
- Wickwire v. ReineckeSupreme Court of the United States · 1927
- Hellmich v. HellmanSupreme Court of the United States · 1928
- Hershey Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Guild v. CommissionerUnited States Board of Tax Appeals · 1930
- Gossett v. CommissionerUnited States Board of Tax Appeals · 1931
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