Northwest Bancorporation v. Commissioner
United States Tax Court
Prior to May 1, 1936, petitioner agreed in writing that it would not declare or pay any dividends (except stock dividends) without the written consent of the Reconstruction Finance Corporation until three conditions should have been fulfilled. It complied with two of these conditions but in the taxable years the third condition was still unfulfilled. Petitioner had only one class of stock, common, and declared no stock dividends thereon.
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Prior to May 1, 1936, petitioner agreed in writing that it would not declare or pay any dividends (except stock dividends) without the written consent of the Reconstruction Finance Corporation until three conditions should have been fulfilled. It complied with two of these conditions but in the taxable years the third condition was still unfulfilled. Petitioner had only one class of stock, common, and declared no stock dividends thereon. Held, that petitioner is entitled to the credit allowed in section 26 (c) (1) of the Revenue Act of 1936.
1Opinion of the Court
Northwest Bancorporation v. Commissioner.
Northwest Bancorporation v. Commissioner
Docket Nos. 103109, 103413.
United States Tax Court
1943 Tax Ct. Memo LEXIS 417; 1 T.C.M. (CCH) 745; T.C.M. (RIA) 43117;
March 6, 1943
Prior to May 1, 1936, petitioner agreed in writing that it would not declare or pay any dividends (except stock dividends) without the written consent of the Reconstruction Finance Corporation until three conditions should have been fulfilled. It complied with two of these conditions but in the taxable years the third condition was still unfulfilled. Petitioner had only one class of…
2Cases cited11 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Helvering v. GriffithsSupreme Court of the United States · 1943
- United States v. Dakota Tractor & Equipment Co.Court of Appeals for the Eighth Circuit · 1942
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