Legal Opinion

Adams v. Commissioner

United States Tax Court

Decided June 29, 1945No. Docket No. 4109Published

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

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Helvering v. GowranSupreme Court of the United States · 1937
  3. United States v. PhellisSupreme Court of the United States · 1921
  4. Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
  5. Commissioner v. WheelerSupreme Court of the United States · 1945

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