Legal Opinion

Georgia Eng'g Co. v. Commissioner

United States Board of Tax Appeals

Decided December 3, 1930No. Docket No. 28143Published

1. Held that certain distributions authorized by the formal action of the petitioner's directors and credited to the accounts of the respective stockholders were dividends, and that the unpaid portion of such dividends was properly excluded from petitioner's invested capital. 2. Certain indebtedness owing to the petitioner and charged off in 1921 held not to have been ascertained to be worthless in that year; held, further, that the debt was ascertained to be worthless in…

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1. Held that certain distributions authorized by the formal action of the petitioner's directors and credited to the accounts of the respective stockholders were dividends, and that the unpaid portion of such dividends was properly excluded from petitioner's invested capital. 2. Certain indebtedness owing to the petitioner and charged off in 1921 held not to have been ascertained to be worthless in that year; held, further, that the debt was ascertained to be worthless in 1923 and the previous charge-off remaining on the books is sufficient to entitle petitioner to the deduction in 1923.

1Opinion of the Court

GEORGIA ENGINEERING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Georgia Eng'g Co. v. Commissioner

Docket No. 28143.

United States Board of Tax Appeals

21 B.T.A. 532; 1930 BTA LEXIS 1838;

December 3, 1930, Promulgated

1. Held that certain distributions authorized by the formal action of the petitioner's directors and credited to the accounts of the respective stockholders were dividends, and that the unpaid portion of such dividends was properly excluded from petitioner's invested capital.

2. Certain indebtedness owing to the petitioner and charged off in 1921 held not to have…

2Cases cited1 opinion

  1. Georgia Eng'g Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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