Charles O. Finley & Co. v. Commissioner
United States Tax Court
Held: (1) Payments of $1,000,000 and $25,000 made by the corporate petitioner to petitioner-husband were dividends and not repayments of loans. These amounts are includible in petitioner-husband's gross income. Sec. 301(c)(1), I.R.C. 1954. (2) The corporate petitioner's working capital did not exceed the reasonable needs of its business. The corporate petitioner is not liable for the accumulated earnings tax imposed by section 531, I.R.C. 1954.
1Opinion of the Court
CHARLES O. FINLEY AND COMPANY, INC., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Charles O. Finley & Co. v. Commissioner
Docket Nos. 8342-71, 8343-71, 7219-73, 7220-73.
United States Tax Court
T.C. Memo 1982-354; 1982 Tax Ct. Memo LEXIS 396; 44 T.C.M. (CCH) 225; T.C.M. (RIA) 82354;
June 22, 1982.
Held: (1) Payments of $1,000,000 and $25,000 made by the corporate petitioner to petitioner-husband were dividends and not repayments of loans. These amounts are includible in petitioner-husband's gross income. Sec. 301(c)(1), I.R.C. 1954.(2) The corporate petitioner's working…
2Cases cited28 opinions
- Helvering v. MitchellSupreme Court of the United States · 1938
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Dixie Dairies Corp. v. CommissionerUnited States Tax Court · 1980
23 more not listed; retrieve them via the Exa API.