Adams v. Commissioner
United States Tax Court
Debentures distributed to petitioner by a corporation of which he was the principal common stockholder in connection with elimination of old common stock and issuance of new without par value, held, on facts failing to show corporate business purpose for the transaction, to constitute a taxable dividend to the extent of their value and of the corporation's accumulated earnings, notwithstanding that surplus account remained unchanged on corporate books.
1Opinion of the Court
Adam A. Adams, Petitioner, v. Commissioner of Internal Revenue, Respondent
Adams v. Commissioner
Docket No. 4109
United States Tax Court
5 T.C. 351; 1945 U.S. Tax Ct. LEXIS 132;
June 29, 1945, Promulgated
Decision will be entered for the respondent.
Debentures distributed to petitioner by a corporation of which he was the principal common stockholder in connection with elimination of old common stock and issuance of new without par value, held, on facts failing to show corporate business purpose for the transaction, to constitute a taxable dividend to the extent of their value and of the…
Also in this document: Dissent · Kern; Dissent · Arundell.
2Cases cited14 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. GowranSupreme Court of the United States · 1937
- United States v. PhellisSupreme Court of the United States · 1921
- Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
- Commissioner v. WheelerSupreme Court of the United States · 1945
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