Legal Opinion

Gowran v. Commissioner

United States Board of Tax Appeals

Decided June 27, 1935No. Docket Nos. 60890-60893Published

DIVIDENDS. - Where both common and preferred shares are outstanding when a dividend is declared upon voting common stock and paid in nonvoting cumulative preferred shares at par value, such dividend is not a tax-free stock dividend. Tillotson Manufacturing Co. v. Commissioner, 76 Fed.(2d) 189, affirming 27 B.T.A. 913; James H. Torrens,31 B.T.A. 787, followed.

1Opinion of the Court

H. C. GOWRAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

EDITH ROSE SUDDARD, AS EXECUTRIX OF THE ESTATE OF THOMAS SUDDARD, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

GEORGE S. HAMILTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

EDWARD P. HAMILTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Gowran v. Commissioner

Docket Nos. 60890-60893.

United States Board of Tax Appeals

32 B.T.A. 820; 1935 BTA LEXIS 883;

June 27, 1935, Promulgated

DIVIDENDS. - Where both common and preferred shares are outstanding when a dividend is…

2Cases cited3 opinions

  1. Tillotson Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  2. TORRENS v. COMMISSIONERUnited States Board of Tax Appeals · 1934
  3. Gowran v. CommissionerUnited States Board of Tax Appeals · 1935

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