Globe-News Publishing Co. v. Commissioner
United States Tax Court
Under plan of recapitalization, old preferred stock of petitioner, on which were dividends in arrears, was exchanged for new preference stock, common stock, and dividend scrip of petitioner, plus cash. Held, under the facts, that "dividend scrip" is not a taxable dividend, and that petitioner is entitled to a dividends paid credit only to the extent of the cash paid.
1Opinion of the Court
OPINION.
Tuenek, Judge:
Petitioner contends that it is “entitled to dividends paid credit in the amount of the adjusted net income on the basis of dividends paid to the old preferred stockholders of $1 per share in cash and dividends paid and/or available in Dividend Scrip to the old preferred stockholders under section 27 (d) of the Revenue Act of 1936,1 or other applicable provisions” of that act.
Respondent claims that the gain or income on the exchange by the preferred stockholders of old preferred stock for new preference stock, plus new common stock, scrip, and cash, pursuant to the plan…
2Cases cited2 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Knapp Monarch Co. v. CommissionerUnited States Tax Court · 1942
3Cited by13 opinions
- Camp Wolters Enterprises, Inc. v. CommissionerUnited States Tax Court · 1954
- Wolf Envelope Co. v. CommissionerUnited States Tax Court · 1951
- Bernstein v. CommissionerUnited States Tax Court · 1954
- Camp Wolters Enterprises v. CommissionerUnited States Tax Court · 1954
- Carman v. CommissionerUnited States Tax Court · 1949
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