Legal Opinion
Commissioner of Internal Revenue v. Goldwyn
Court of Appeals for the Ninth Circuit
Decided June 20, 1949No. 12037PublishedCited by 16 opinions
1Opinion of the Court
ORR, Circuit Judge.
In 1942 respondent received a distribution in the amount of $800,000 from Samuel Goldwyn Studios, Inc., a corporation in which respondent owned all the outstanding shares. The principal source of the distribution was a reduction surplus created by corporate resolution reducing the par value of the capital stock and the stated capital of the corporation. The Commissioner determined that the sum of $239,059.-58 of the distribution was from accumulated and current earnings and therefore constituted a taxable dividend. See § 115(a) and (b) and § 22(a) of the Internal Revenue…
2Cases cited7 opinions
- United States v. GuinzburgCourt of Appeals for the Second Circuit · 1921
- Commissioner of Internal Revenue v. ScatenaCourt of Appeals for the Ninth Circuit · 1936
- Commissioner of Internal Rev. v. TR Miller Mill Co.Court of Appeals for the Fifth Circuit · 1939
- Bulger Block Coal Co. v. United StatesUnited States Court of Claims · 1931
- W. E. Caldwell Co. v. CommissionerUnited States Board of Tax Appeals · 1927
2 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
- Fehrs Finance Co. v. CommissionerUnited States Tax Court · 1972
- Stephens v. CommissionerUnited States Tax Court · 1973
- McKelvy v. United StatesUnited States Court of Claims · 1973
- Bush Bros. & Co. v. CommissionerUnited States Tax Court · 1979
11 more not listed; retrieve them via the Exa API.