Hill v. Commissioner
United States Board of Tax Appeals
Cancellation or redemption of stock and the resultant distribution may be treated as a taxable dividend under provisions of section 201(g) of the Revenue Act of 1926, although there is no proof of existing relation between the issuance of the stock and its redemption evidencing a continuing, unified plan for distribution of surplus.
1Opinion of the Court
OPINION.
Goodeioh :
This proceeding involves the redetermination of a deficiency of $4,741.98 for the year 1927, of which the amount of $2,726.65 is in controversy. Only one issue is raised, namely, whether the amount of $25,000 received by the petitioner in 1927 in redemption of 250 shares of Union Bleachery, issued to her as a stock dividend in 1922, should be treated as essentially equivalent to the distribution of an ordinary dividend under section 201 (g) of the Revenue Act of 1926, or as a distribution in partial liquidation under section 201 (c) of that act. The facts were stipulated,…
2Cited by16 opinions
- Flanagan v. HelveringCourt of Appeals for the D.C. Circuit · 1940
- Boehringer v. CommissionerUnited States Board of Tax Appeals · 1933
- Adler v. CommissionerUnited States Board of Tax Appeals · 1934
- Curlee v. CommissionerUnited States Board of Tax Appeals · 1933
- Straub v. CommissionerUnited States Board of Tax Appeals · 1933
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