Legal Opinion

Bradley v. Commissioner

United States Board of Tax Appeals

Decided November 29, 1924No. Docket No. 47Published

The transfer in 1919 by a corporation of stock or other property to a stockholder, in common with other stockholders and in proportion to stock held in the corporation, for one-eighth of its value and under other circumstances revealed by the evidence is not a sale in good faith but is a taxable dividend, when received by the stockholder, as defined by section 201(a) of the Revenue Act of 1918, and must be included in his net income subject to surtax for the year in question.

1Opinion of the Court

Appeal of W. C. BRADLEY.

Bradley v. Commissioner

Docket No. 47.

United States Board of Tax Appeals

1 B.T.A. 111; 1924 BTA LEXIS 242;

November 29, 1924, decided Submitted October 29, 1924.

The transfer in 1919 by a corporation of stock or other property to a stockholder, in common with other stockholders and in proportion to stock held in the corporation, for one-eighth of its value and under other circumstances revealed by the evidence is not a sale in good faith but is a taxable dividend, when received by the stockholder, as defined by section 201(a) of the Revenue Act of 1918, and must be…

2Cases cited1 opinion

  1. Bradley v. CommissionerUnited States Board of Tax Appeals · 1924

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