F. Brody & Sons Co. v. Commissioner
United States Tax Court
Under the facts, held, that a certain distribution made by petitioner to its stockholders in 1918 was a cash dividend and that the stock simultaneously issued to its then stockholders in proportion to their existing stock holdings in return for checks received from said stockholders was sold to the stockholders for cash and the amount thereof should be included in petitioner's equity invested capital.
1Opinion of the Court
F. Brody and Sons Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
F. Brody & Sons Co. v. Commissioner
Docket No. 12128
United States Tax Court
11 T.C. 298; 1948 U.S. Tax Ct. LEXIS 91;
September 16, 1948, Promulgated
Decision will be entered for the petitioner.
Under the facts, held, that a certain distribution made by petitioner to its stockholders in 1918 was a cash dividend and that the stock simultaneously issued to its then stockholders in proportion to their existing stock holdings in return for checks received from said stockholders was sold to the stockholders for cash…
Also in this document: Dissent.
2Cases cited3 opinions
- United States v. MellonCourt of Appeals for the Third Circuit · 1922
- United States v. MellonDistrict Court, W.D. Pennsylvania · 1919
- F. Brody & Sons Co. v. CommissionerUnited States Tax Court · 1948