Hobson v. Commissioner
United States Tax Court
Arthur L. Hobson and George W. Langdon, Jr., executed an agreement by the terms of which the former agreed to sell and the latter agreed to purchase certain shares of stock. The total consideration involved was $ 36,250, payable over a designated period of time. During such period, which was later extended, Hobson was to remain record owner and in possession of the shares until the agreed amount was fully paid.
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Arthur L. Hobson and George W. Langdon, Jr., executed an agreement by the terms of which the former agreed to sell and the latter agreed to purchase certain shares of stock. The total consideration involved was $ 36,250, payable over a designated period of time. During such period, which was later extended, Hobson was to remain record owner and in possession of the shares until the agreed amount was fully paid. He was also to credit any and all dividends paid to him by reason thereof against such purchase price. Held: Dividends received by Hobson in 1943, 1944, and 1945, by reason of his…
1Opinion of the Court
OPINION.
Van Fossan, Judge:
[Respondent has conceded that $2,614.10 of the $16,250 distributed by Bradley-Goodrich, Inc., in 1943 was properly reported by Hobson. As for the remainder of the distributions made during the period under review, respondent contends that they were taxable dividends within the meaning of section 115 (a), Internal Revenue Code.1 This contention is not disputed by petitioners. It is agreed by all that some one owes the tax. The decision as to which petitioners are taxable on such dividends constitutes the sole issue herein.
The facts briefly summarized are these: On…
2Cases cited10 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Bingham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1939
- Moore v. CommissionerCourt of Appeals for the Seventh Circuit · 1941
- De Guire v. HigginsCourt of Appeals for the Second Circuit · 1947
5 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Pacific Coast Music Jobbers, Inc. v. CommissionerUnited States Tax Court · 1971
- Pacific Coast Music Jobbers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1972
- Steel Improv. & Forge Co. v. CommissionerUnited States Tax Court · 1961
- Christensen v. CommissionerUnited States Tax Court · 1959
- Wilson v. CommissionerUnited States Tax Court · 1957
19 more not listed; retrieve them via the Exa API.