St. Clair Estate Co. v. Commissioner
United States Tax Court
1. In 1936 petitioner, a personal holding company, credited to its stockholders' accounts as dividends the total amount of $ 10,000, which was made unconditionally subject to their unrestricted demand in that year.
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1. In 1936 petitioner, a personal holding company, credited to its stockholders' accounts as dividends the total amount of $ 10,000, which was made unconditionally subject to their unrestricted demand in that year. In 1937 petitioner drew checks in favor of the stockholders in amounts which included the $ 10,000 dividend declared in 1936. Held, petitioner is not entitled to a dividends paid credit in 1937 on account of the $ 10,000 dividends credited to and constructively received by the stockholders in 1936. 2. Dividends were declared by petitioner in 1938 and the amount thereof was credited…
1Opinion of the Court
St. Clair Estate Co., a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
St. Clair Estate Co. v. Commissioner
Docket Nos. 105112, 108827, 109162
United States Tax Court
9 T.C. 392; 1947 U.S. Tax Ct. LEXIS 101;
September 24, 1947, Promulgated
Decisions will be entered under Rule 50.
1. In 1936 petitioner, a personal holding company, credited to its stockholders' accounts as dividends the total amount of $ 10,000, which was made unconditionally subject to their unrestricted demand in that year. In 1937 petitioner drew checks in favor of the stockholders in amounts which…
Also in this document: Dissent · Hill; Dissent · Disney.
2Cases cited10 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- Hellmich v. HellmanSupreme Court of the United States · 1928
- Foster v. United StatesSupreme Court of the United States · 1938
- Shellabarger Grain Products Co. v. CommissionerUnited States Tax Court · 1943
- Senior Inv. Corp. v. CommissionerUnited States Tax Court · 1943
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