Silco, Inc. v. United States

Appellant Silco, Inc., appeals a district court decision denying its recovery of corporate federal income taxes and interest. The Internal Revenue Service (IRS) assessed these taxes against Silco when it determined that Silco improperly reported dividends on stock purchased after the corporate record date as income. The issue turns on whether the term “entitled” in the applicable Treasury Regulation is defined by (1) the stock exchange rules which follow the economic reality of the subject stock sales transactions or, (2) by the legal status conferred by corporate stock dividend declarations.…