Legal Opinion

Crown Iron Works Co. v. Commissioner

United States Tax Court

Decided August 29, 1956No. Docket No. 52992Unpublished

Held: The shares of preferred stock on which five per cent return was paid by the petitioner in the years 1949 and 1950 constituted capital stock rather than indebtedness and the amounts so paid were dividends.

1Opinion of the Court

Crown Iron Works Company, a corporation v. Commissioner.

Crown Iron Works Co. v. Commissioner

Docket No. 52992.

United States Tax Court

T.C. Memo 1956-199; 1956 Tax Ct. Memo LEXIS 92; 15 T.C.M. (CCH) 1046; T.C.M. (RIA) 56199;

August 29, 1956

Held: The shares of preferred stock on which five per cent return was paid by the petitioner in the years 1949 and 1950 constituted capital stock rather than indebtedness and the amounts so paid were dividends.

O. A. Brecke, Esq., McKnight Building, Minneapolis, Minn., for the petitioner. Claude R. Sanders, Esq., for the respondent.

BRUCE

Memorandum Findings of…

2Cases cited8 opinions

  1. John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
  2. Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
  3. Estate of Miller v. CommissionerUnited States Tax Court · 1955
  4. Gillespie Trust v. CommissionerUnited States Tax Court · 1954
  5. Northern Refrigerator Line, Inc. v. CommissionerUnited States Tax Court · 1943

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