Legal Opinion

Stranahan v. Commissioner

United States Board of Tax Appeals

Decided September 28, 1926No. Docket Nos. 75, 76Published

1. Dividends paid in 1917 are taxable at 1917 rates to the extent of 1917 earnings available for distribution at the time of the declaration of the dividend. Edwards v. Douglas,269 U.S. 204; 46 Sup.Ct. 85; 5 Am.Fed. Tax Rep. 5666. 2. Commissioner's finding by pro rata method that one-sixth of 1917 earnings was available for distribution on March 1, 1917, approved. Douglas v. Edwards,287 Fed. 919; 2 Am. Fed. Tax Rep. 1890.

1Opinion of the Court

APPEALS OF ELIZABETH W. STRANAHAN AND FRANK D. STRANAHAN.

Stranahan v. Commissioner

Docket Nos. 75, 76.

United States Board of Tax Appeals

4 B.T.A. 1141; 1926 BTA LEXIS 2052;

September 28, 1926, Decided

1. Dividends paid in 1917 are taxable at 1917 rates to the extent of 1917 earnings available for distribution at the time of the declaration of the dividend. Edwards v. Douglas,269 U.S. 204; 46 Sup.Ct. 85; 5 Am.Fed. Tax Rep. 5666.

2. Commissioner's finding by pro rata method that one-sixth of 1917 earnings was available for distribution on March 1, 1917, approved. Douglas v. Edwards,287 Fed. 919; 2…

2Cases cited5 opinions

  1. Edwards v. DouglasSupreme Court of the United States · 1925
  2. Douglas v. EdwardsCourt of Appeals for the Second Circuit · 1924
  3. Douglas v. EdwardsDistrict Court, S.D. New York · 1922
  4. Appeal of J. S. Hoskins Lumber Co.United States Board of Tax Appeals · 1926
  5. Stranahan v. CommissionerUnited States Board of Tax Appeals · 1926

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