Great Lakes Coco-Cola Bottling Co. v. Commissioner

SPARKS, Circuit Judge.

The taxpayer petitioned for review of a decision of the United States Tax Court denying its claim to a dividends paid credit in the amount of its adjusted net income for the year 1937 under § 27(f) of the Revenue Act of 1936/26 U.S.C.A. Int.Rev.Acts, page 838, relating to amounts distributed in liquidation.

There is no controversy as to the facts. The Tax Court stated them substantially as follows: In November 1937, the taxpayer, in pursuance of a plan of reorganization, transferred all its assets, including its earnings for the period from January 1, 1937, to a group of…