Legal Opinion

Ward M. Canaday, Inc. v. Commissioner

United States Board of Tax Appeals

Decided November 15, 1933No. Docket No. 58632Published

1. A distribution by a corporation of all of its assets in excess of an amount equal to the par value of its outstanding capital stock, held, a distribution in liquidation rather than an ordinary dividend, where, some months before the distribution, it had disposed of all of the assets with which it theretofore had conducted its business for stock and notes and thereafter limited its activities to the conversion into cash of some of the securities received and the retirement…

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1. A distribution by a corporation of all of its assets in excess of an amount equal to the par value of its outstanding capital stock, held, a distribution in liquidation rather than an ordinary dividend, where, some months before the distribution, it had disposed of all of the assets with which it theretofore had conducted its business for stock and notes and thereafter limited its activities to the conversion into cash of some of the securities received and the retirement of stock of a certain class and, on the same day when the distribution, supra, was authorized and made, it passed a…

1Opinion of the Court

WARD M. CANDAY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Ward M. Canaday, Inc. v. Commissioner

Docket No. 58632.

United States Board of Tax Appeals

29 B.T.A. 355; 1933 BTA LEXIS 954;

November 15, 1933, Promulgated

1. A distribution by a corporation of all of its assets in excess of an amount equal to the par value of its outstanding capital stock, held, a distribution in liquidation rather than an ordinary dividend, where, some months before the distribution, it had disposed of all of the assets with which it theretofore had conducted its business for stock and notes and…

2Cases cited1 opinion

  1. Ward M. Canaday, Inc. v. CommissionerUnited States Board of Tax Appeals · 1933

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