Cook v. United States

LITTLETON, Judge.

We think it is clear from the facts that the plaintiff received a taxable liquidating dividend in 1920. His claim that such liquidating dividend, if the purported sale of assets by the corporation was not effective as such, was received on December 31, 1919, and was not, therefore, taxable in 1920, cannot be sustained. The corporation carried on the business in its corporate capacity until 12 o’clock midnight, December 31, 1919. Upon the close of business at that hour, plaintiff liquidated the corporation, received its assets, and assumed its liabilities. The corporation was…