Perry v. Commissioner
United States Board of Tax Appeals
1. A dividend declared on December 31, 1925, and credited on that date to the petitioners' account on the books of the corporation is income for 1925, even though not actually withdrawn until 1926. 2. An amount paid by the petitioners in the taxable year to reimburse a corporation for interest paid by it in 1924 and 1925 on indebtedness secured by their home, is not deductible.
1Opinion of the Court
OPINION.
Lansdon :
The respondent has asserted deficiencies against the petitioners for 1926 in the respective amounts of $833.68 and $860.93. There are two questions presented for determination: (1) Where a corporate dividend is declared on December 31, 1925, and credited on that date to the petitioners’ account on the books of the corporation, does it constitute income for 1925, or should it be included as income in 1926 when it is withdrawn? and (2) Are the petitioners entitled to a deduction in 1926 for amounts paid to a corporation in that year to reimburse it for interest paid in 1924 and…
2Cases cited2 opinions
- Braxton v. CommissionerUnited States Board of Tax Appeals · 1931
- Hopkins v. CommissionerUnited States Board of Tax Appeals · 1933
3Cited by16 opinions
- Wilkerson v. CommissionerUnited States Tax Court · 1978
- Heyman v. CommissionerUnited States Tax Court · 1978
- M. O. Rife and Maidee W. Rife v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Granan v. CommissionerUnited States Tax Court · 1971
- Menz v. CommissionerUnited States Tax Court · 1983
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