Legal Opinion
Angelus Building & Investment Co. v. Com'r of Int. Rev.
Court of Appeals for the Ninth Circuit
Decided March 21, 1932No. 6579PublishedCited by 8 opinions
1Opinion of the Court
JAMES, District Judge.
In this proceeding, brought by the petitioner corporation, to review a decision of the Board o^ Tax Appeals, there is presented the question whether certain payments, made by the petitioner in 1922 to persons listed as holders of its stock, are to be considered as dividends, or as interest on money borrowed. If the former, they were not deductible from gross revenue in computing income tax; if the latter, they ■ were deductible. The Commissioner held that the payments were dividends distributed to shareholders, and hence were not deductible. The Board of Tax Appeals…
2Cases cited5 opinions
- Elko Lamoille Power Co. v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1931
- Osburn California Corporation v. WelchCourt of Appeals for the Ninth Circuit · 1930
- California Iron Yards Co. v. Commissioner of Internal Rev.Court of Appeals for the Ninth Circuit · 1931
- Fidelity-Philadelphia Trust Co. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1931
- Garrison Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1932
3Cited by8 opinions
- Commissioner of Int. Rev. v. Meridian & Thirteenth R. Co.Court of Appeals for the Seventh Circuit · 1942
- Lodi Iron Works, Inc. v. CommissionerUnited States Tax Court · 1958
- Bell Bakeries, Inc. v. Jefferson Standard Life InsuranceSupreme Court of North Carolina · 1957
- Faris v. HelveringCourt of Appeals for the Ninth Circuit · 1934
- Guaranty Trust Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1943
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