Legal Opinion

Falmouth Co. v. Commissioner

United States Board of Tax Appeals

Decided December 17, 1941No. Dockets Nos. 104454, 104455PublishedCited by 7 opinions

Dividends on corporate stock which when declared became a debt in favor of petitioner, a stockholder on the accrual basis, held returnable as income in the year of declaration.

1Opinion of the Court

opinion.

Opper:

Respondent determined the following deficiencies in petitioners’ income tax liability for the year 1936:

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The single issue in each proceeding is whether a dividend, declared during the tax year, is taxable to petitioners who are on the accrual basis. All the facts in each proceeding have been stipulated and as so stipulated are hereby adopted as our findings. The stipulation in its entirety is as follows:

1. The Petitioner,, Tar Products Corporation, .was incorporated under the laws of the State of Rhode Island on July 2, • 1920, with its principal office at the…

2Cases cited1 opinion

  1. Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934

3Cited by7 opinions

  1. Frelbro Corp. v. CommissionerUnited States Tax Court · 1961
  2. Tar Products Corporation v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1942
  3. Commissioner of Internal Rev. v. AMERICAN L. & T. CO.Court of Appeals for the Seventh Circuit · 1946
  4. Cox v. CommissionerUnited States Tax Court · 1982
  5. Cox v. CommissionerUnited States Tax Court · 1982

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