Joseph L. O'Brien Co. v. Commissioner
United States Tax Court
On December 7, 1954, American, the owner of shares of stock in General, entered into an arrangement to sell the stock at a stated price subject to the happening of stated conditions. The arrangement provided that if the sale was consummated as therein provided, all dividends thereafter paid or payable on the stock should be the "property" of the purchaser and should be paid to the purchaser at the time of the payment of the purchase price of the stock.
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On December 7, 1954, American, the owner of shares of stock in General, entered into an arrangement to sell the stock at a stated price subject to the happening of stated conditions. The arrangement provided that if the sale was consummated as therein provided, all dividends thereafter paid or payable on the stock should be the "property" of the purchaser and should be paid to the purchaser at the time of the payment of the purchase price of the stock. Previously General had declared certain dividends on its stock payable December 31, 1954, to stockholders of record on December 20, 1954. At…
1Opinion of the Court
Joseph L. O'Brien Co., Petitioner, v. Commissioner of Internal Revenue, Respondent
Joseph L. O'Brien Co. v. Commissioner
Docket No. 69785
United States Tax Court
35 T.C. 750; 1961 U.S. Tax Ct. LEXIS 225;
February 13, 1961, Filed
Decision will be entered under Rule 50.
On December 7, 1954, American, the owner of shares of stock in General, entered into an arrangement to sell the stock at a stated price subject to the happening of stated conditions. The arrangement provided that if the sale was consummated as therein provided, all dividends thereafter paid or payable on the stock should be the…
2Cases cited3 opinions
- Rupe Investment Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Rupe Inv. Corp. v. CommissionerUnited States Tax Court · 1958
- Joseph L. O'Brien Co. v. CommissionerUnited States Tax Court · 1961