Cohen v. Commissioner
United States Board of Tax Appeals
Amounts of debit balances as of December 31, 1924, standing on books of corporation as accounts receivable and representing withdrawals previously made by petitioners from corporation in which they were stockholders held to be income to them not when withdrawals were made, but in 1928 when, by appropriate corporate action, the balances were canceled and charged against surplus.
1Opinion of the Court
*192OPINION.
Goodrich:
It is conceded that the amounts received by each of these petitioners from the corporation fall within the statutory definition 1 of “ dividends ” — a distribution to the shareholders out of profits accumulated since February 28, 1913 — but there is dispute as to the time when the distribution was made and when the amounts, appearing on the books as accounts receivable, became dividends to be included in income. Respondent contends that the distribution was made and the amounts became dividends in 1928 when the accounts were charged off against the corporate surplus, and has…
2Cases cited3 opinions
- Wood v. CommissionerUnited States Board of Tax Appeals · 1932
- Miller v. CommissionerUnited States Board of Tax Appeals · 1932
- Lincoln Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1931
3Cited by11 opinions
- Miller v. CommissionerUnited States Tax Court · 1981
- Estate of Miller v. CommissionerUnited States Tax Court · 1978
- Shephard v. CommissionerUnited States Tax Court · 1963
- Waggaman v. CommissionerUnited States Board of Tax Appeals · 1933
- Weisberger v. CommissionerUnited States Board of Tax Appeals · 1933
6 more not listed; retrieve them via the Exa API.