Citizens Federal Sav. & Loan Ass'n v. Commissioner
United States Tax Court
Respondent determined that petitioner, a Federal savings and loan association, was not entitled to deduct in 1952, the first year in which it was subject to the corporate income tax, dividends declared on its net earnings for the 6-months' period ended December 31, 1951. Held, on the facts, dividends credited to petitioner's "savings account" shareholders as of December 31, 1951, were not deductible by petitioner in 1952. Held, further, since the dividends payable by…
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Respondent determined that petitioner, a Federal savings and loan association, was not entitled to deduct in 1952, the first year in which it was subject to the corporate income tax, dividends declared on its net earnings for the 6-months' period ended December 31, 1951. Held, on the facts, dividends credited to petitioner's "savings account" shareholders as of December 31, 1951, were not deductible by petitioner in 1952. Held, further, since the dividends payable by petitioner to its "investment" shareholders for the period ended December 31, 1951, were paid by checks dated January 2, 1952,…
1Opinion of the Court
Bruce, Judge:
Respondent determined deficiencies in petitioner’s income tax as follows:
Tear Deficiency
1952_$5,168.52
1953_ 3, 724.67
The sole issue is whether dividends in the amount of $29,695.95 declared by petitioner on its earnings for the 6-months’ period ended December 31,1951, were allowable as a deduction in 1952.
findings of fact.
Most of the facts have been stipulated and the stipulation, together with the exhibits attached thereto, is made a part hereof by this reference.
Petitioner is a Federal savings and loan association with offices located in Covington, Kentucky. Its corporation…
2Cases cited10 opinions
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Avery v. CommissionerSupreme Court of the United States · 1934
- National Airlines, Inc. v. CommissionerUnited States Tax Court · 1947
- Gulf Power Co. v. CommissionerUnited States Tax Court · 1948
- Jenkins v. BitgoodCourt of Appeals for the Second Circuit · 1939
5 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- World Airways, Inc. v. CommissionerUnited States Tax Court · 1974
- Peoples Bank & Trust Co. v. CommissionerUnited States Tax Court · 1968
- Ernst v. CommissionerUnited States Tax Court · 1959
- Washington Federal Savings & Loan Ass'n v. United StatesDistrict Court, S.D. Florida · 1969
- Hancock County Federal Savings & Loan Ass'n v. CommissionerUnited States Tax Court · 1959
9 more not listed; retrieve them via the Exa API.