C. Blake McDowell, Inc. v. Commissioner
United States Tax Court
Petitioner, a personal holding company, paid deficiency dividends partly in cash and partly in other property which had a fair market value in excess of its adjusted basis in petitioner's hands.
Read the full summary
Petitioner, a personal holding company, paid deficiency dividends partly in cash and partly in other property which had a fair market value in excess of its adjusted basis in petitioner's hands. Held, sec. 1.562-1(a), Income Tax Regs., providing that the measure of the dividends-paid deduction for purposes of the personal holding company tax is the adjusted basis of the property, is valid, following Fulman v. United States, 545 F.2d 268 (1st Cir. 1976). Held, further, despite the foregoing, the Court is required to hold for petitioner herein in view of H. Wetter Manufacturing Co. v. United…
1Opinion of the Court
C. Blake McDowell, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
C. Blake McDowell, Inc. v. Commissioner
Docket No. 3852-76
United States Tax Court
67 T.C. 1043; 1977 U.S. Tax Ct. LEXIS 130;
March 30, 1977, Filed
Petitioner, a personal holding company, paid deficiency dividends partly in cash and partly in other property which had a fair market value in excess of its adjusted basis in petitioner's hands. Held, sec. 1.562-1(a), Income Tax Regs., providing that the measure of the dividends-paid deduction for purposes of the personal holding company tax is the adjusted basis of the…
Also in this document: Concurrence · Drennen; Concurrence · Goffe; Concurrence · Wilbur.
2Cases cited14 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CartwrightSupreme Court of the United States · 1973
- Ivan Allen Co. v. United StatesSupreme Court of the United States · 1975
- The H. Wetter Manufacturing Company v. United StatesCourt of Appeals for the Sixth Circuit · 1972
9 more not listed; retrieve them via the Exa API.