Legal Opinion
Cranson v. United States
Court of Appeals for the Ninth Circuit
Decided January 24, 1945No. 10644PublishedCited by 5 opinions
1Opinion of the Court
GARRECHT, Circuit Judge.
The question here is whether the distribution of $450 to the taxpayer from the Honolulu Oil Corporation, Ltd., hereinafter referred to as Honolulu constituted a taxable dividend. The taxpayer is suing to recover income taxes paid on this distribution in 1936.
The facts are stipulated and were adopted by the court below as its findings of facts.
On August 31, 1936, Honolulu liquidated three wholly owned subsidiaries and took over their assets subject to their liabilities, in complete cancellation and redemption of all their issued and outstanding capital stock. When…
2Cases cited5 opinions
- Commissioner of Internal Revenue v. SansomeCourt of Appeals for the Second Circuit · 1932
- Pearce v. CommissionerSupreme Court of the United States · 1942
- Foley Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1938
- Long Beach Improv. Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Allen v. CommissionerCourt of Appeals for the Fourth Circuit · 1939
3Cited by5 opinions
- Commissioner v. PhippsSupreme Court of the United States · 1949
- United States v. GallagherCourt of Appeals for the Ninth Circuit · 1945
- Commissioner v. PhippsCourt of Appeals for the Tenth Circuit · 1948
- First Nat. Ben. Soc. v. StuartCourt of Appeals for the Ninth Circuit · 1946
- Shuman v. United StatesCourt of Appeals for the Ninth Circuit · 1945