Miller v. Commissioner
United States Tax Court
Dividends -- Reduction of Authorized Capital Represented by No-Par Common Stock -- Surplus Credited to Stockholders. -- A corporation reduced its authorized capital represented by no-par common stock in 1936 from $ 50,000 to $ 2,500, credited the difference to capital surplus, and over 21 months later transferred the amount from capital surplus to stockholders' accounts pro rata.
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Dividends -- Reduction of Authorized Capital Represented by No-Par Common Stock -- Surplus Credited to Stockholders. -- A corporation reduced its authorized capital represented by no-par common stock in 1936 from $ 50,000 to $ 2,500, credited the difference to capital surplus, and over 21 months later transferred the amount from capital surplus to stockholders' accounts pro rata. A distribution to a cash basis stockholder in 1948, accounted for by the corporation as a payment on account of the balance in the account in the stockholder's name, was a dividend distribution within the meaning of…
1Opinion of the Court
Joseph H. Miller and Rose B. Miller, Petitioners, v. Commissioner of Internal Revenue, Respondent. Samuel Miller and Emma S. Miller, Petitioners, v. Commissioner of Internal Revenue, Respondent
Miller v. Commissioner
Docket Nos. 51489, 51492
United States Tax Court
26 T.C. 115; 1956 U.S. Tax Ct. LEXIS 212;
April 20, 1956, Filed
Decisions will be entered for the respondent.
Dividends -- Reduction of Authorized Capital Represented by No-Par Common Stock -- Surplus Credited to Stockholders. -- A corporation reduced its authorized capital represented by no-par common stock in 1936 from $ 50,000 to $…
2Cases cited7 opinions
- BERETTA v. COMMISSIONERUnited States Tax Court · 1942
- Beretta v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1944
- Leland v. CommissionerCourt of Appeals for the First Circuit · 1931
- Long v. CommissionerUnited States Tax Court · 1945
- Long v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1946
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