Le Blanc v. Commissioner
United States Board of Tax Appeals
A stockholder of a corporation who, to protect and conserve his own business interests, enters into an agreement with an employee of the corporation that such employee shall receive the dividends upon his shares of stock so long as the employee shall remain with the corporation, is entitled to deduct the amounts of the dividends paid to the employee as a business expense.
1Opinion of the Court
*259OPINION.
SteRnhagen:
The primary question is whether the dividends on petitioner’s stock during the years in question are part of his income notwithstanding the fact that, because of his instruction to the corporation, they were not received by him but paid directly to his son Stewart. The question is essentially the same as that involved in Samuel V. Woods, 5 B. T. A. 413; Fred W. Warner, 5 B. T. A. 963; Providence & Worcester R. R. Co., 5 B. T. A. 1186, and in Rensselaer & Saratoga R. R. Co. v. Irwin, 239 Fed. 739; affd. 249 Fed. 726; certiorari denied 246 U. S. 671.
The petitioner was himself…
2Cases cited2 opinions
- Rensselaer & S. R. v. IrwinCourt of Appeals for the Second Circuit · 1918
- Rensselaer & S. R. v. IrwinDistrict Court, N.D. New York · 1917
3Cited by16 opinions
- Estate of Frank D. Stranahan, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1973
- Novotny v. CommissionerUnited States Tax Court · 1989
- Caruth v. United StatesDistrict Court, N.D. Texas · 1987
- Christie Coal & Coke Co. v. CommissionerUnited States Tax Court · 1969
- Estate of Stranahan v. CommissionerUnited States Tax Court · 1971
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