Legal Opinion

Midwest Sav. Asso. v. Commissioner

United States Tax Court

Decided November 13, 1980No. Docket No. 7918-78PublishedCited by 3 opinions

A building and loan association paid or credited a bonus distribution to depositors or to the accounts of depositors on Sept. 30, 1972. At the close of business on Sept. 30, 1972, pursuant to a previously adopted agreement, the building and loan association merged into another building and loan association. Held, the bonus distribution is deductible as a dividend under sec. 591, I.R.C. 1954.

1Opinion of the Court

OPINION

Ekman, Judge:*

Respondent determined deficiencies in petitioner’s Federal income taxes for the taxable years ending December 31, 1969, December 31, 1970, December 31, 1971, the taxable period January 1 through September 30, 1972,1 and the taxable year ending December 31,1973,2 as follows:

Year Deficiency

1969 ' $2,608.72

1970 3,177.67

1971 3,844.35

Jan. 1 through Sept. 30, 1972 2,336.79

1973 21,022.46

Concessions having been made by petitioner, the sole issue remaining for decision is whether a distribution to depositor shareholders by a domestic building and loan association may be deducted…

2Cases cited13 opinions

  1. Waterman Steamship Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
  2. Verito v. CommissionerUnited States Tax Court · 1965
  3. Steel Improv. & Forge Co. v. CommissionerUnited States Tax Court · 1961
  4. International Trading Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
  5. The Steel Improvement and Forge Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1963

8 more not listed; retrieve them via the Exa API.

3Cited by3 opinions

  1. Monson v. CommissionerUnited States Tax Court · 1982
  2. Midwest Sav. Asso. v. CommissionerUnited States Tax Court · 1980
  3. Monson v. CommissionerUnited States Tax Court · 1982

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