Connelly v. Commissioner
United States Board of Tax Appeals
1. Held, that rights to subscribe to bonds of the American Telephone & Telegraph Co. issued to stockholders of that company are not income.
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1. Held, that rights to subscribe to bonds of the American Telephone & Telegraph Co. issued to stockholders of that company are not income. T. I. Hare Powel,27 B.T.A. 55. 2. The cancellation and retirement of preferred stock owned by the petitioners in the taxable years held not to have been made under circumstances essentially equivalent to the distribution of taxable dividends so as to make the amounts distributed taxable as dividends under the provisions of section 115(g) of the Revenue Act of 1928.
1Opinion of the Court
*332OPINION.
Matthews:
These proceedings, which have been consolidated, are for the redetermination of deficiencies in income tax as follows:
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All the issues raised by the pleadings, except two, were settled by a written stipulation signed by the parties and filed at the hearing, and effect will be given thereto in the redetermination of the deficiencies under Eule 50.
The main issue submitted for our determination, which is common to each of the proceedings, is whether the respondent erred in treating as taxable dividends the amounts received by the petitioners from the J. G. Curtis…
2Cases cited8 opinions
- Brown v. CommissionerUnited States Board of Tax Appeals · 1932
- Hill v. CommissionerUnited States Board of Tax Appeals · 1932
- Babson v. CommissionerUnited States Board of Tax Appeals · 1933
- Powel v. CommissionerUnited States Board of Tax Appeals · 1932
- KOCH v. COMMISSIONERUnited States Board of Tax Appeals · 1932
3 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Connelly v. CommissionerUnited States Board of Tax Appeals · 1934
- McGuire v. CommissionerUnited States Board of Tax Appeals · 1935
- Natwick v. CommissionerUnited States Board of Tax Appeals · 1937