Legal Opinion

Anderson v. Commissioner

United States Tax Court

Decided December 22, 1976No. Docket No. 1727-74Published

Petitioners, as stockholders of Associates, the parent corporation of an affiliated group, received distributions from Associates during the year 1971 with respect to their stock. The basic issue is whether the entire amount of the distributions was taxable to petitioners as ordinary dividends or whether a part thereof was nontaxable as a return of capital.

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Petitioners, as stockholders of Associates, the parent corporation of an affiliated group, received distributions from Associates during the year 1971 with respect to their stock. The basic issue is whether the entire amount of the distributions was taxable to petitioners as ordinary dividends or whether a part thereof was nontaxable as a return of capital. Determination of the basic issue requires determination of several subsidiary issues involving the effect on the earnings and profits of Associates and its subsidiaries of various transactions that occurred during the computation years. 1.…

1Opinion of the Court

Ronald D. Anderson and Marilyn J. Anderson, Petitioners v. Commissioner of Internal Revenue, Respondent

Anderson v. Commissioner

Docket No. 1727-74

United States Tax Court

67 T.C. 522; 1976 U.S. Tax Ct. LEXIS 4;

December 22, 1976, Filed

Decision will be entered under Rule 155.

Petitioners, as stockholders of Associates, the parent corporation of an affiliated group, received distributions from Associates during the year 1971 with respect to their stock. The basic issue is whether the entire amount of the distributions was taxable to petitioners as ordinary dividends or whether a part thereof was…

2Cases cited46 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. Knowlton v. MooreSupreme Court of the United States · 1900
  4. Dixon v. United StatesSupreme Court of the United States · 1965
  5. Enoch v. CommissionerUnited States Tax Court · 1972

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