Commissioner of Internal Revenue v. Maurice Fox

BIGGS, Chief Judge.

The taxpayer, on a cash basis, owned investment shares in one hundred federal savings and loan associations scattered throughout the United States. The controversy concerns the proper year for the taxation of dividends of twenty-seven of these associations, all located outside New Jersey where the taxpayer had his residence. The associations declared year-end dividends payable on or before December 31, 1949. The taxpayer could have collected his dividends had he appeared on that day at the offices of the respective companies and had requested payment. Actually the dividends…