Inland Investors, Inc. v. Commissioner
United States Board of Tax Appeals
At the beginning of 1936 petitioner had no earnings or profits accumulated after February 28, 1913. It distributed in 1936 $125,000. In the same year it sustained net capital losses and, under section 117(d), $43,541.42 thereof was not deductible. Petitioner's net income was $124,934.58. Petitioner accepts the respondent's determination that part of the distributions made in 1936 were nontaxable distributions in the hands of its shareholders.
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At the beginning of 1936 petitioner had no earnings or profits accumulated after February 28, 1913. It distributed in 1936 $125,000. In the same year it sustained net capital losses and, under section 117(d), $43,541.42 thereof was not deductible. Petitioner's net income was $124,934.58. Petitioner accepts the respondent's determination that part of the distributions made in 1936 were nontaxable distributions in the hands of its shareholders. Respondent determined that petitioner's earnings and profits for 1936 were $80,751.64 and allowed a dividends paid credit in that amount under section…
1Opinion of the Court
INLAND INVESTORS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Inland Investors, Inc. v. Commissioner
Docket No. 100784.
United States Board of Tax Appeals
44 B.T.A. 654; 1941 BTA LEXIS 1297;
June 5, 1941, Promulgated
At the beginning of 1936 petitioner had no earnings or profits accumulated after February 28, 1913. It distributed in 1936 $125,000. In the same year it sustained net capital losses and, under section 117(d), $43,541.42 thereof was not deductible. Petitioner's net income was $124,934.58. Petitioner accepts the respondent's determination that part of the…
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