Crown v. Commissioner
United States Tax Court
On Mar. 10, 1966, GD paid a dividend on its common stock, without paying or setting aside for payment a dividend on its preferred stock for the first quarter of 1966. On Mar. 14, 1966, a plan for the redemption of the preferred stock was adopted, and the redemption price expressly included an amount representing the unpaid dividend for the first quarter of 1966. Held: (1) Under the terms of GD's certificate of incorporation, the dividends on the preferred stock must be…
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On Mar. 10, 1966, GD paid a dividend on its common stock, without paying or setting aside for payment a dividend on its preferred stock for the first quarter of 1966. On Mar. 14, 1966, a plan for the redemption of the preferred stock was adopted, and the redemption price expressly included an amount representing the unpaid dividend for the first quarter of 1966. Held: (1) Under the terms of GD's certificate of incorporation, the dividends on the preferred stock must be declared and paid, or set apart for payment, before common stock dividends are declared or paid; (2) as a result of the…
1Opinion of the Court
SimfsoN, Judge:
The respondent determined deficiencies in the petitioners’ income taxes for the year 1966: as follows:
Petitioner Deficiency
Arie S. Crown_$55,669. 64
James S. Crown- 33,141. 57
Patricia A. Crown_ 28, 749. 60
Daniel M. Crown_ 22, 457.34
Petitioner Deficiency
Debra L. Crown_$26, 098.36
Nancy J. Crown_ 175.42
Richard C. Goodman_ 3,429. 35
Laurie J. Crown_ 2, 308.99
Most of the issues in this case have been settled; the one issue remaining for decision is whether all the proceeds received by a petitioner when his stock was redeemed are taxable as a capital gain under section 302 (a) of the…
2Cases cited18 opinions
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Waterman Steamship Corp. v. United StatesSupreme Court of the United States · 1965
- C. M. Gooch Lumber Sales Co. v. CommissionerUnited States Tax Court · 1968
- Jorden v. CommissionerUnited States Tax Court · 1948
- Mathis v. CommissionerUnited States Tax Court · 1966
13 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Victor E. Gidwitz Family Trust v. CommissionerUnited States Tax Court · 1974
- Braddock Land Co. v. CommissionerUnited States Tax Court · 1980
- Fisher v. CommissionerUnited States Tax Court · 1974
- Braddock Land Co. v. CommissionerUnited States Tax Court · 1980
- Crown v. CommissionerUnited States Tax Court · 1972
2 more not listed; retrieve them via the Exa API.