Crown v. Commissioner
United States Tax Court
On Mar. 10, 1966, GD paid a dividend on its common stock, without paying or setting aside for payment a dividend on its preferred stock for the first quarter of 1966. On Mar. 14, 1966, a plan for the redemption of the preferred stock was adopted, and the redemption price expressly included an amount representing the unpaid dividend for the first quarter of 1966. Held: (1) Under the terms of GD's certificate of incorporation, the dividends on the preferred stock must be…
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On Mar. 10, 1966, GD paid a dividend on its common stock, without paying or setting aside for payment a dividend on its preferred stock for the first quarter of 1966. On Mar. 14, 1966, a plan for the redemption of the preferred stock was adopted, and the redemption price expressly included an amount representing the unpaid dividend for the first quarter of 1966. Held: (1) Under the terms of GD's certificate of incorporation, the dividends on the preferred stock must be declared and paid, or set apart for payment, before common stock dividends are declared or paid; (2) as a result of the…
1Opinion of the Court
Arie S. Crown, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Crown v. Commissioner
Docket Nos. 3359-70 -- 3366-70
United States Tax Court
58 T.C. 825; 1972 U.S. Tax Ct. LEXIS 73;
August 14, 1972, Filed
Decisions will be entered under Rule 50.
On Mar. 10, 1966, GD paid a dividend on its common stock, without paying or setting aside for payment a dividend on its preferred stock for the first quarter of 1966. On Mar. 14, 1966, a plan for the redemption of the preferred stock was adopted, and the redemption price expressly included an amount representing the unpaid dividend for…
2Cases cited19 opinions
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Waterman Steamship Corp. v. United StatesSupreme Court of the United States · 1965
- C. M. Gooch Lumber Sales Co. v. CommissionerUnited States Tax Court · 1968
- Jorden v. CommissionerUnited States Tax Court · 1948
- Mathis v. CommissionerUnited States Tax Court · 1966
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