Cloutier v. Commissioner
United States Tax Court
Petitioners were shareholders of a corporation which distributed cash and property to them during the taxable years 1948 and 1949. The fair market value of the property distributed in each year exceeded both its adjusted basis to the corporation and the total accumulated and current earnings or profits of the corporation for each year.
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Petitioners were shareholders of a corporation which distributed cash and property to them during the taxable years 1948 and 1949. The fair market value of the property distributed in each year exceeded both its adjusted basis to the corporation and the total accumulated and current earnings or profits of the corporation for each year. However, the adjusted basis of the property distributed during 1948 was greater than the corporation's earnings or profits, while that of the property distributed during 1949 was less. Held, the total fair market value of the distributions made during each year…
1Opinion of the Court
Harry Handley Cloutier and Elinor S. Cloutier, Husband and Wife, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Cloutier v. Commissioner
Docket Nos. 47445, 47446, 47447
United States Tax Court
24 T.C. 1006; 1955 U.S. Tax Ct. LEXIS 103;
September 19, 1955, Filed
Decisions will be entered under Rule 50.
Petitioners were shareholders of a corporation which distributed cash and property to them during the taxable years 1948 and 1949. The fair market value of the property distributed in each year exceeded both its adjusted basis to the corporation and the total accumulated and…
2Cases cited14 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Lynch v. HornbySupreme Court of the United States · 1918
- Peabody v. EisnerSupreme Court of the United States · 1918
- R. D. Merrill Co. v. CommissionerUnited States Tax Court · 1945
- Gross v. CommissionerUnited States Tax Court · 1955
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