Legal Opinion

National Sec. Series--Industrial Stocks Series v. Commissioner

United States Tax Court

Decided December 2, 1949No. Docket Nos. 19617, 19618, 19619, 19620PublishedCited by 2 opinions

Each of the petitioners is an open end investment trust whose shareholders are entitled at any time, at their option, to surrender their shares for redemption and receive the proportionate share of the underlying trust assets and net earnings to the date of surrender.

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Each of the petitioners is an open end investment trust whose shareholders are entitled at any time, at their option, to surrender their shares for redemption and receive the proportionate share of the underlying trust assets and net earnings to the date of surrender. During the taxable periods in question, each of the petitioners, incident to the redemption of its shares, made distributions of net earnings to its shareholders and included such sums as dividends paid in the computation of its basic surtax credit. Held, that the accumulated net earnings distributed by the petitioners during…

1Opinion of the Court

OPINION.

Arundell, Judge:

These cases, consolidated for trial and opinion, involve the following deficiencies in income taxes:

Docket No. Taxable period Deficiency

19617» Aug. 1,1944, to Apr. 30, 1945.... $86.70

19618» Fiscal year ended Apr. 30,1945. 1,962.30

19619» Aug. 1,1944, to Apr. 30, 1945_ 207.47

19620» Fiscal year ended Apr. 30, 1945. 1,933.44

The petitioners are unincorporated investment trusts whose Federal income tax returns for the taxable periods involved herein were filed on a cash basis with the collector of internal revenue for the second district of New York. In the case of each…

2Cases cited2 opinions

  1. United Artists Theatre Circuit, Inc. v. CommissionerUnited States Tax Court · 1943
  2. New York Stocks, Inc. v. CommissionerUnited States Tax Court · 1947

3Cited by2 opinions

  1. H. H. King Flour Mills Co. v. United StatesDistrict Court, D. Minnesota · 1971
  2. National Sec. Series--Industrial Stocks Series v. CommissionerUnited States Tax Court · 1949

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