Legal Opinion

Spreckels v. Commissioner

United States Tax Court

Decided December 27, 1949No. Docket Nos. 5628, 5629, 5677, 5678Published

1. Dividends. -- The extent to which distributions received by petitioners as stockholders of the J. D. & A. B. Spreckels Co. during 1938, 1939, and 1940 constituted taxable dividends is by stipulation to be determined pursuant to the opinion in Grace H. Kelham, 13 T. C. 984. 2. Id. -- Where under section 186, Revenue Act of 1942, a personal holding company filed a claim for relief from personal holding company surtax on account of a distribution to its sole stockholder,…

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1. Dividends. -- The extent to which distributions received by petitioners as stockholders of the J. D. & A. B. Spreckels Co. during 1938, 1939, and 1940 constituted taxable dividends is by stipulation to be determined pursuant to the opinion in Grace H. Kelham, 13 T. C. 984. 2. Id. -- Where under section 186, Revenue Act of 1942, a personal holding company filed a claim for relief from personal holding company surtax on account of a distribution to its sole stockholder, accompanied by the stockholder's consent to the inclusion of the full amount of such distribution in her gross income as a…

1Opinion of the Court

Adolph B. Spreckels, Petitioner, et al., * v. Commissioner of Internal Revenue, Respondent

Spreckels v. Commissioner

Docket Nos. 5628, 5629, 5677, 5678

United States Tax Court

13 T.C. 1079; 1949 U.S. Tax Ct. LEXIS 4;

December 27, 1949, Promulgated

Decision in each proceeding will be entered under Rule 50.

1. Dividends. -- The extent to which distributions received by petitioners as stockholders of the J. D. & A. B. Spreckels Co. during 1938, 1939, and 1940 constituted taxable dividends is by stipulation to be determined pursuant to the opinion in Grace H. Kelham, 13 T. C. 984.

2. Id. -- Where under…

2Cases cited2 opinions

  1. Kelham v. CommissionerUnited States Tax Court · 1949
  2. Spreckels v. CommissionerUnited States Tax Court · 1949

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