Natural Gasoline Corp. v. Commissioner
United States Tax Court
A dividend resolution by petitioner's board of directors provided for the distribution of certain securities and did not create to that extent a monetary obligation which was satisfied by the distribution of such securities; accordingly, petitioner realized no recognizable loss on the transaction.
1Opinion of the Court
OPINION.
Kaum, Judge:
The question before us is whether the distribution by petitioner of the Warren Petroleum Corporation stock as a dividend to its stockholders was a transaction in which the petitioner realized a loss which is recognizable for tax purposes. The petitioner’s argument is that the declaration of the dividend by the petitioner’s board of directors created a monetary obligation to the stockholders which was satisfied by the distribution of the stock and a recognizable loss was suffered. The contention of the Commissioner is that it was intended at the outset that the Warren stock…
2Cases cited3 opinions
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
- Helvering v. General Utilities & Operating Co.Court of Appeals for the Fourth Circuit · 1935
- Commissioner of Internal Rev. v. Columbia Pacific S. Co.Court of Appeals for the Ninth Circuit · 1935
3Cited by2 opinions
- Louisiana Irrigation & Mill Co. v. CommissionerUnited States Tax Court · 1955
- Natural Gasoline Corp. v. CommissionerUnited States Tax Court · 1953