Corporate Inv. Co. v. Commissioner
United States Board of Tax Appeals
1. LOSS ON STOCK. - The distribution of stock of other corporations as a dividend does not give rise to deductible loss where the dividend resolution provides for payment in the stock, following General Utilities & Operating Co. v. Helvering,296 U.S. 200. 2. ACCRUED INTEREST AND CHARGES. - The evidence does not sustain respondent's affirmative allegation that he erred in allowing in 1929 part of a deduction for accrued interest and charges on amounts received by the…
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1. LOSS ON STOCK. - The distribution of stock of other corporations as a dividend does not give rise to deductible loss where the dividend resolution provides for payment in the stock, following General Utilities & Operating Co. v. Helvering,296 U.S. 200. 2. ACCRUED INTEREST AND CHARGES. - The evidence does not sustain respondent's affirmative allegation that he erred in allowing in 1929 part of a deduction for accrued interest and charges on amounts received by the petitioner under contracts with its shareholder where the contracts themselves and the consistent interpretation of them by the…
1Opinion of the Court
*1168OPINION.
MurdoCk:
The two issues raised by the respondent will be discussed first, since they may have some bearing upon the main issue. The case of General Utilities & Operating Co. v. Helvering, 296 U. S. 200, is controlling on the question of whether the distribution of the Loew and Chase stocks resulted in deductible losses. The dividend resolution in that case provided for a dividend of a certain amount payable in a named stock at a declared valuation. The Court held that no sale of the stock resulted and the stock was not used to discharge an indebtedness. Here the dividend resolution was…
2Cases cited4 opinions
- Helvering v. MitchellSupreme Court of the United States · 1938
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
3Cited by15 opinions
- American Metal Products Corp. v. CommissionerUnited States Tax Court · 1960
- Gpd, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1974
- Bardahl Mfg. Corp. v. CommissionerUnited States Tax Court · 1965
- GPD, Inc. v. CommissionerUnited States Tax Court · 1973
- World Pub. Co. v. United StatesDistrict Court, N.D. Oklahoma · 1947
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