Maguire v. Commissioner
United States Tax Court
Dividend -- Earnings and Profits of Taxable Year -- Accumulated Deficit -- Sec. 115 (a ) (2), I. R. C. -- A dividend as defined in section 115 (a) of the Code includes a distribution made by a corporation to its stockholders out of earnings and profits of the taxable year even though those earnings and profits were not sufficient to wipe out an accumulated deficit existing at the beginning of the taxable year.
1Opinion of the Court
William G. Maguire, Petitioner, v. Commissioner of Internal Revenue, Respondent
Maguire v. Commissioner
Docket No. 39802
United States Tax Court
21 T.C. 853; 1954 U.S. Tax Ct. LEXIS 276;
March 5, 1954, Promulgated
Decision will be entered for the respondent.
Dividend -- Earnings and Profits of Taxable Year -- Accumulated Deficit -- Sec. 115 (a ) (2), I. R. C. -- A dividend as defined in section 115 (a) of the Code includes a distribution made by a corporation to its stockholders out of earnings and profits of the taxable year even though those earnings and profits were not sufficient to wipe out an…
2Cases cited4 opinions
- Helvering v. Alworth TrustCourt of Appeals for the Eighth Circuit · 1943
- Maguire v. CommissionerUnited States Tax Court · 1954
- Lehman v. CommissionerUnited States Tax Court · 1944
- Ratterman v. CommissionerCourt of Appeals for the Sixth Circuit · 1949