Legal Opinion

Hub Dress Mfg. Co. v. Commissioner

United States Board of Tax Appeals

Decided December 18, 1924No. Docket No. 283Published

A corporation may not deduct the value of securities transferred by it to its principal stockholder in consideration of his agreement to transfer at the request of the corporation from time to time, portions of the capital stock owned by him directly to employees of the corporation. The corporation may deduct as salaries paid the value of its stock transferred to such employees at the time when such transfers take place.

1Opinion of the Court

Appeal of HUB DRESS MANUFACTURING CO.

Hub Dress Mfg. Co. v. Commissioner

Docket No. 283.

United States Board of Tax Appeals

1 B.T.A. 197; 1924 BTA LEXIS 212;

December 18, 1924, decided Submitted November 13, 1924.

A corporation may not deduct the value of securities transferred by it to its principal stockholder in consideration of his agreement to transfer at the request of the corporation from time to time, portions of the capital stock owned by him directly to employees of the corporation. The corporation may deduct as salaries paid the value of its stock transferred to such employees at the…

2Cases cited1 opinion

  1. Hub Dress Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1924

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