Legal Opinion

Owensboro Wagon Co. v. Commissioner

United States Tax Court

Decided September 25, 1952No. Docket No. 25835Published

Prior to March 1, 1913, petitioner paid certain dividends of its common stock on common stock. Held, that the dividends are not includible in equity invested capital as distributions of stock under section 718 (a) (3) (A), I. R. C.

1Opinion of the Court

Owensboro Wagon Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Owensboro Wagon Co. v. Commissioner

Docket No. 25835

United States Tax Court

18 T.C. 1107; 1952 U.S. Tax Ct. LEXIS 92;

September 25, 1952, Promulgated

Decision will be entered for the respondent.

Prior to March 1, 1913, petitioner paid certain dividends of its common stock on common stock. Held, that the dividends are not includible in equity invested capital as distributions of stock under section 718 (a) (3) (A), I. R. C.

James E. Fahey, Esq., for the petitioner.

R. G. de Quevedo, Esq., for the respondent.

Johnson,…

2Cases cited13 opinions

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. Koshland v. HelveringSupreme Court of the United States · 1936
  3. Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
  4. P. Dougherty Co. v. CommissionerUnited States Tax Court · 1945
  5. Foster v. United StatesSupreme Court of the United States · 1938

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