Legal Opinion

de Bretteville Spreckels v. Commissioner

United States Tax Court

Decided December 27, 1949No. Docket No. 5741UnpublishedCited by 3 opinions

Dividends. - The extent to which distributions received by petitioner on stock of the J. D. and A. B. Spreckels Company during 1938, 1939, and 1940 constituted taxable dividends is, by stipulation, to be determined pursuant to the opinion in Grace H. Kelham, et al., 13 T.C. - (No. 125). Deduction: Bad debt. - On the facts, held that petitioner is entitled to a bad debt deduction for the year 1939. Earned income credit. - Held, that the amount thereof be recomputed under Rule…

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Dividends. - The extent to which distributions received by petitioner on stock of the J. D. and A. B. Spreckels Company during 1938, 1939, and 1940 constituted taxable dividends is, by stipulation, to be determined pursuant to the opinion in Grace H. Kelham, et al., 13 T.C. - (No. 125). Deduction: Bad debt. - On the facts, held that petitioner is entitled to a bad debt deduction for the year 1939. Earned income credit. - Held, that the amount thereof be recomputed under Rule 50.

1Opinion of the Court

Alma de Bretteville Spreckels (formerly Alma Spreckels Awl) v. Commissioner.

de Bretteville Spreckels v. Commissioner

Docket No. 5741.

United States Tax Court

1949 Tax Ct. Memo LEXIS 8; 8 T.C.M. (CCH) 1113; T.C.M. (RIA) 49299;

December 27, 1949

Dividends. - The extent to which distributions received by petitioner on stock of the J. D. and A. B. Spreckels Company during 1938, 1939, and 1940 constituted taxable dividends is, by stipulation, to be determined pursuant to the opinion in Grace H. Kelham, et al., 13 T.C. - (No. 125).

Deduction: Bad debt. - On the facts, held that petitioner is entitled to…

2Cases cited3 opinions

  1. Edward Katzinger Co. v. CommissionerUnited States Board of Tax Appeals · 1941
  2. Jarvis v. CommissionerUnited States Board of Tax Appeals · 1941
  3. Bunker Hill & Sullivan Mining & Concentrating Co. v. CommissionerUnited States Tax Court · 1943

3Cited by3 opinions

  1. Byerlite Corporation v. Parker C. Williams, District Director of Internal Revenue, Eighteenth District of OhioCourt of Appeals for the Sixth Circuit · 1960
  2. Earle, Collector of Internal Revenue v. W. J. Jones & Son, Inc. United States v. W. J. Jones & Son, IncCourt of Appeals for the Ninth Circuit · 1952
  3. Troop Water Heater Co. v. BinglerDistrict Court, W.D. Pennsylvania · 1964

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