Legal Opinion

Henry C. Beck Co. v. Commissioner

United States Tax Court

Decided April 3, 1969No. Docket No. 1686-66Published

In 1955, Management, a corporation wholly owned by petitioner and its joint venturer, Utah, distributed $ 250,000 to petitioner. The distribution was made by Management from a profit "realized" in 1954 from its two wholly owned corporations, but which it did not "recognize" for income tax purposes because of filing a consolidated return.

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In 1955, Management, a corporation wholly owned by petitioner and its joint venturer, Utah, distributed $ 250,000 to petitioner. The distribution was made by Management from a profit "realized" in 1954 from its two wholly owned corporations, but which it did not "recognize" for income tax purposes because of filing a consolidated return. Petitioner treated the distribution as an ordinary dividend, deducting 85 percent of the distribution under sec. 243, I.R.C. 1954, and reporting the remaining 15 percent as a taxable dividend. Respondent determined that the distribution was not a dividend…

1Opinion of the Court

Henry C. Beck Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Henry C. Beck Co. v. Commissioner

Docket No. 1686-66

United States Tax Court

52 T.C. 1; 1969 U.S. Tax Ct. LEXIS 160;

April 3, 1969, Filed

Decision will be entered for the petitioner.

In 1955, Management, a corporation wholly owned by petitioner and its joint venturer, Utah, distributed $ 250,000 to petitioner. The distribution was made by Management from a profit "realized" in 1954 from its two wholly owned corporations, but which it did not "recognize" for income tax purposes because of filing a consolidated return.…

Also in this document: Dissent.

2Cases cited18 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  3. Commissioner v. GordonSupreme Court of the United States · 1968
  4. Henry C. Beck Builders, Inc. v. CommissionerUnited States Tax Court · 1964
  5. Commissioner of Internal Revenue v. Oscar E. Baan and Evelyn K. BaanCourt of Appeals for the Ninth Circuit · 1967

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