Legal Opinion

American Light & Traction Co. v. Commissioner

United States Tax Court

Decided June 30, 1944No. Docket No. 112415Published

1. Dividends declared in December 1936 to stockholders of record as of dates during that month, but payable in 1937, are income to stockholder petitioner in the latter year, even though it is on an accrual basis. Tar Products Corporation v. Commissioner, 130 Fed.

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1. Dividends declared in December 1936 to stockholders of record as of dates during that month, but payable in 1937, are income to stockholder petitioner in the latter year, even though it is on an accrual basis. Tar Products Corporation v. Commissioner, 130 Fed. (2d) 866, followed. 2. Since the Wisconsin Privilege Dividend Tax Law, ch. 505, Laws of 1935, as amended, imposes the burden of that tax upon the stockholder, the stockholder may deduct the same under section 23 (c) of the Revenue Acts of 1934 and 1936. Wisconsin Gas & Electric Co. v. United States, 322 U.S. 526.

1Opinion of the Court

American Light & Traction Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

American Light & Traction Co. v. Commissioner

Docket No. 112415

United States Tax Court

3 T.C. 1048; 1944 U.S. Tax Ct. LEXIS 96;

June 30, 1944, Promulgated

Decision will be entered under Rule 50.

1. Dividends declared in December 1936 to stockholders of record as of dates during that month, but payable in 1937, are income to stockholder petitioner in the latter year, even though it is on an accrual basis. Tar Products Corporation v. Commissioner, 130 Fed. (2d) 866, followed.

2. Since the Wisconsin Privilege…

2Cases cited2 opinions

  1. Wisconsin Gas & Electric Co. v. United StatesSupreme Court of the United States · 1944
  2. American Light & Traction Co. v. CommissionerUnited States Tax Court · 1944

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