L. J. Christopher Co. v. Commissioner
United States Board of Tax Appeals
1. Certain withdrawals from a corporation made by a stockholder who owned all the stock of the corporation except certain qualifying shares, held to be taxable dividends under section 201 of the Revenue Act of 1921. 2. In the absence of evidence showing when income-tax returns were filed, held, that the assessment of a deficiency is not barred by the statute of limitations. 3. The value of the good will of a corporation determined. 4. Right to special assessment under…
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1. Certain withdrawals from a corporation made by a stockholder who owned all the stock of the corporation except certain qualifying shares, held to be taxable dividends under section 201 of the Revenue Act of 1921. 2. In the absence of evidence showing when income-tax returns were filed, held, that the assessment of a deficiency is not barred by the statute of limitations. 3. The value of the good will of a corporation determined. 4. Right to special assessment under section 328 of the Revenue Act of 1921 denied where the only facts established in evidence are the amount of income and the…
1Opinion of the Court
*737OPINION.
Milliken :
Respondent has determined that L. J. Christopher received in the year 1921 from the California Company taxable dividends in the net amount of $192,872.67, computed as follows:
2/15/1921 — -Balance due L. J. Christopher Co. (Calif. Corp.)_$66,464.81
2/15/1921- — -Cash received from L. J. Christopher Co. of Delaware on sale of assets by the L. J. Christopher Co. of California to the L. J. Christopher Co. of Delaware_ 125,000.00
Cash received from L. J. Christopher Co. of Delaware in cancellation of 250 shares preferred stock, the property of L. J. Christopher Co. of California_…
2Cited by14 opinions
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- Iverson v. CommissionerUnited States Board of Tax Appeals · 1934
- C. F. Mueller Co. v. CommissionerUnited States Tax Court · 1970
- United States v. SkolnickDistrict Court, S.D. New York · 1957
- Campbell v. CommissionerUnited States Tax Court · 1961
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