Legal Opinion
Helvering v. Sabine Transportation Co.
Supreme Court of the United States
Decided March 1, 1943No. 518PublishedCited by 24 opinions
1Opinion of the CourtJustice Roberts
In this case the Circuit Court of Appeals held the respondent entitled to include in its dividends paid credit, pursuant to § 271 of the Revenue Act of 1938, the amount paid to redeem notes given for dividends in a prior year.2 The Circuit Court of Appeals of the Ninth Circuit had held to the contrary.3 To resolve the conflict we granted certiorari.
In 1937 the respondent paid dividends, $30,000 in cash and $530,000 in its ten year eight per cent notes. As respects its liability for undistributed profits tax, it claimed and was allowed, pursuant to § 27 (d) of the Revenue Act of 1936,4 as part…
2Cases cited3 opinions
- Helvering v. Credit Alliance Corp.Supreme Court of the United States · 1942
- Sabine Transp. Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1942
- Spokane Dry Goods Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
3Cited by24 opinions
- Social Security Board v. NierotkoSupreme Court of the United States · 1946
- Regents of the University System of Georgia v. CarrollSupreme Court of the United States · 1950
- United States v. Lawrence G. EmpeyCourt of Appeals for the Tenth Circuit · 1969
- Hanley v. United StatesUnited States Court of Claims · 1945
- Hugh A. O'Neill and Elizabeth O'Neill v. United StatesCourt of Appeals for the Sixth Circuit · 1969
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