Legal Opinion

Boyle v. Commissioner

United States Tax Court

Decided June 30, 1950No. Docket No. 21624Published

Petitioner's share of payments received from a corporation by him and the two other principal stockholders in exchange for a portion of the stock, being made for no corporate reason and not affecting petitioner's ultimate proportional interest in the company, held on facts essentially equivalent to the distribution of a taxable dividend. Section 115 (g), Internal Revenue Code.

1Opinion of the Court

James F. Boyle, Petitioner, v. Commissioner of Internal Revenue, Respondent

Boyle v. Commissioner

Docket No. 21624

United States Tax Court

14 T.C. 1382; 1950 U.S. Tax Ct. LEXIS 135;

June 30, 1950, Promulgated

Decision will be entered for the respondent.

Petitioner's share of payments received from a corporation by him and the two other principal stockholders in exchange for a portion of the stock, being made for no corporate reason and not affecting petitioner's ultimate proportional interest in the company, held on facts essentially equivalent to the distribution of a taxable dividend. Section 115…

2Cases cited4 opinions

  1. United States v. KatzSupreme Court of the United States · 1926
  2. Dr. Pepper Bottling Co. v. CommissionerUnited States Tax Court · 1942
  3. Murphy v. CasselmanNorth Dakota Supreme Court · 1913
  4. Boyle v. CommissionerUnited States Tax Court · 1950

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