Legal Opinion
Commissioner of Internal Rev. v. AMERICAN L. & T. CO.
Court of Appeals for the Seventh Circuit
Decided July 3, 1946No. 8845PublishedCited by 16 opinions
1Opinion of the Court
SPARKS, Circuit Judge.
This is a petition to review a decision of the Tax Court that dividends declared in December, 1936, to stockholders of record as of dates during that month, but payable in 1937, are income to the taxpayer in the latter year even though, it is on an accrual basis.
In rendering its decision, the Tax Court stated that in the case of Falmouth Co. v. Com'r (Tar Products Corporation v. Com’r), reported in 45 B.T.A. 1033, the court had before it a similar state of facts, and that it there held that the date of declaration and not the date fixed for payment controlled the…
2Cases cited10 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Avery v. CommissionerSupreme Court of the United States · 1934
- Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
- Mason v. RoutzahnSupreme Court of the United States · 1927
5 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Allied Fidelity Corp. v. CommissionerUnited States Tax Court · 1976
- Frelbro Corp. v. CommissionerUnited States Tax Court · 1961
- Beneficial Corp. v. CommissionerUnited States Tax Court · 1952
- Dynamics Corporation of America (Formerly Claude Neon, Inc.) v. The United StatesUnited States Court of Claims · 1968
- The Denver & Rio Grande Western Railroad Company, a Corporation v. The United StatesUnited States Court of Claims · 1963
11 more not listed; retrieve them via the Exa API.