Continental Nat'l Bank & Trust Co. v. Commissioner
United States Board of Tax Appeals
The decedent received dividends on January 15, April 15, July 15, and October 15, 1922, from a corporation which on January 1, 1921, had no undistributed earnings or profits accumulated since February 28, 1913, and which corporation sustained a loss of $896,168.23 for the first six months of 1921, realized a profit of $346,724.17 for the last six months of 1921, sustained a loss of $141,175.74 for the first six months of 1922, and realized a profit of $390,365.92 for the…
Read the full summary
The decedent received dividends on January 15, April 15, July 15, and October 15, 1922, from a corporation which on January 1, 1921, had no undistributed earnings or profits accumulated since February 28, 1913, and which corporation sustained a loss of $896,168.23 for the first six months of 1921, realized a profit of $346,724.17 for the last six months of 1921, sustained a loss of $141,175.74 for the first six months of 1922, and realized a profit of $390,365.92 for the last six months of 1922. Held that in determining whether the dividends paid in 1922 were paid from earnings or profits…
1Opinion of the Court
CONTINENTAL NATIONAL BANK & TRUST CO., AS EXECUTOR, ESTATE OF MILTON H. WILSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Continental Nat'l Bank & Trust Co. v. Commissioner
Docket No. 26814.
United States Board of Tax Appeals
20 B.T.A. 829; 1930 BTA LEXIS 2019;
September 16, 1930, Promulgated
The decedent received dividends on January 15, April 15, July 15, and October 15, 1922, from a corporation which on January 1, 1921, had no undistributed earnings or profits accumulated since February 28, 1913, and which corporation sustained a loss of $896,168.23 for the first six months of…
2Cases cited3 opinions
- Edwards v. DouglasSupreme Court of the United States · 1925
- Mason v. RoutzahnSupreme Court of the United States · 1927
- Continental Nat'l Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930