Allen v. Commissioner
United States Board of Tax Appeals
Corporate stock issued as a stock dividend was redeemed nine years later because of desire to reduce indebtedness to the corporation by the stockholders, in order to have the high credit rating necessary for borrowing at extremely low rates of interest. Held, the stock was not redeemed at such time and in such manner as to make the distribution essentially equivalent to a taxable dividend under section 115(g), Revenue Act of 1934.
1Opinion of the Court
BONA ALLEN, JR., AND EVELYN HEMBREE ALLEN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
VICTOR H. ALLEN AND LUCILE GASTON ALLEN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
ESTATE OF H. WADLEIGH ALLEN, DECEASED, BONA ALLEN, JR., JOHN Q. ALLEN AND VICTOR H. ALLEN, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
JOHN Q. ALLEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Allen v. Commissioner
Docket Nos. 93809, 93810, 93811, 93812.
United States Board of Tax Appeals
41 B.T.A. 206; 1940 BTA LEXIS 1215;
January 30, 1940,…
2Cases cited1 opinion
- Allen v. CommissionerUnited States Board of Tax Appeals · 1940