Ragland Inv. Co. v. Commissioner
United States Tax Court
Petitioner-corporations received 6-percent cumulative preferred stock in partial consideration for assets transferred to the issuing corporation. Held, the payments made to petitioners with respect to this stock were dividends in reality as well as in form, and consequently, petitioners are entitled to the 85-percent dividends-received deduction under sec. 243, I.R.C. 1954.
1Opinion of the Court
Ragland Investment Company, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Ragland Inv. Co. v. Commissioner
Docket Nos. 5980-67, 5981-67, 5982-67
United States Tax Court
52 T.C. 867; 1969 U.S. Tax Ct. LEXIS 69;
August 26, 1969, Filed
Decisions will be entered for the petitioners.
Petitioner-corporations received 6-percent cumulative preferred stock in partial consideration for assets transferred to the issuing corporation. Held, the payments made to petitioners with respect to this stock were dividends in reality as well as in form, and consequently, petitioners are entitled…
Also in this document: Dissent · Tietjens; Dissent · Simpson.
2Cases cited24 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Bazley v. CommissionerSupreme Court of the United States · 1947
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
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