Farrell v. Commissioner
United States Board of Tax Appeals
Petitioners owned stock in a corporation which had an earned surplus on March 1, 1913. Losses which occurred thereafter greater than undistributed earnings of years previous to such losses should be charged to and reduce such earned surplus, but not subsequent earnings. Earnings subsequent to losses so treated are the most recently accumulated earnings, and dividends paid to petitioners therefrom are taxable to them. Helvering v. Canfield,291 U.S. 163.
1Opinion of the Court
ROBERT S. FARRELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
G. A. OLSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Farrell v. Commissioner
Docket Nos. 54294, 54295.
United States Board of Tax Appeals
30 B.T.A. 627; 1934 BTA LEXIS 1295;
May 2, 1934, Promulgated
Petitioners owned stock in a corporation which had an earned surplus on March 1, 1913. Losses which occurred thereafter greater than undistributed earnings of years previous to such losses should be charged to and reduce such earned surplus, but not subsequent earnings. Earnings subsequent to losses so…
2Cases cited2 opinions
- Helvering v. CanfieldSupreme Court of the United States · 1934
- Farrell v. CommissionerUnited States Board of Tax Appeals · 1934