Legal Opinion

E-B Grain Co. v. Commissioner

United States Tax Court

Decided August 3, 1983No. Docket Nos. 4291-82, 4292-82, 4293-82Published

P qualified as an electing small business corporation for its fiscal year ending July 31, 1977. P's small business election was revoked for its fiscal year 1978. The 15th day of the 3d month following the close of P's fiscal year 1977 (i.e., Oct. 15, 1977) fell on a Saturday, and P was closed for business on that date.

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P qualified as an electing small business corporation for its fiscal year ending July 31, 1977. P's small business election was revoked for its fiscal year 1978. The 15th day of the 3d month following the close of P's fiscal year 1977 (i.e., Oct. 15, 1977) fell on a Saturday, and P was closed for business on that date. On Monday, Oct. 17, 1977, P made two distributions to its shareholders (petitioners herein) in respect of their stock, and these distributions did not exceed the shareholders' respective shares of P's undistributed accumulated income at July 31, 1977. Held, when the last day of…

1Opinion of the Court

E-B Grain Co., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

E-B Grain Co. v. Commissioner

Docket Nos. 4291-82, 4292-82, 4293-82

United States Tax Court

81 T.C. 70; 1983 U.S. Tax Ct. LEXIS 58; 81 T.C. No. 6;

August 3, 1983, Filed

Decisions will be entered under Rule 155.

P qualified as an electing small business corporation for its fiscal year ending July 31, 1977. P's small business election was revoked for its fiscal year 1978. The 15th day of the 3d month following the close of P's fiscal year 1977 (i.e., Oct. 15, 1977) fell on a Saturday, and P was closed for business on…

2Cases cited8 opinions

  1. Dixon v. United StatesSupreme Court of the United States · 1965
  2. Malat v. RiddellSupreme Court of the United States · 1966
  3. Jacklin v. CommissionerUnited States Tax Court · 1982
  4. Sherwood Bros. v. District of ColumbiaCourt of Appeals for the D.C. Circuit · 1940
  5. Dittler Bros., Inc. v. CommissionerUnited States Tax Court · 1979

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