Legal Opinion

Continental Nat'l Bank & Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided September 16, 1930No. Docket No. 26814Published

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…

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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

  1. Edwards v. DouglasSupreme Court of the United States · 1925
  2. Mason v. RoutzahnSupreme Court of the United States · 1927
  3. Continental Nat'l Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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