Commissioner of Internal Revenue v. Adams

BINGHAM, Circuit Judge.

This is a petition to review an order or decision of the Board of Tax Appeals reversing a finding of the commissioner in which he determined a deficiency of $4,583.78 against the taxpayer for the year 1924.

The facts are as follows:

In 1924 the taxpayer, a resident of Wellesley Hills, Mass., held fifteen hundred shares of the stock of the Bristol Leather Company of Philadelphia, Pa. December 26, 1924, the board of directors of the leather company, at a special meeting in Philadelphia, declared a dividend in the following manner:

“Upon motion duly seconded, the Treasurer…