Geo. W. Ultch Lumber Co. v. Commissioner
United States Tax Court
1. Prior to March 1, 1913, petitioner made four separate distributions to stockholders. Held: (1) That the distribution of its common on common stock was a dividend which is not includible in equity invested capital as a distribution in stock which comes within section 718 (a) (3) (A), Internal Revenue Code. Owensboro Wagon Co., 18 T. C. 1107, followed.
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1. Prior to March 1, 1913, petitioner made four separate distributions to stockholders. Held: (1) That the distribution of its common on common stock was a dividend which is not includible in equity invested capital as a distribution in stock which comes within section 718 (a) (3) (A), Internal Revenue Code. Owensboro Wagon Co., 18 T. C. 1107, followed. (2) That each of three other distributions in stock are includible in equity invested capital under section 718 (a) (3) (A) since such distributions in stock represented distributions of earnings and profits; on the facts Owensboro Wagon Co.,…
1Opinion of the Court
The Geo. W. Ultch Lumber Co., Petitioner, v. Commissioner of Internal Revenue, Respondent
Geo. W. Ultch Lumber Co. v. Commissioner
Docket No. 30930
United States Tax Court
21 T.C. 382; 1953 U.S. Tax Ct. LEXIS 10;
December 23, 1953, Promulgated
Decision will be entered under Rule 50.
1. Prior to March 1, 1913, petitioner made four separate distributions to stockholders. Held: (1) That the distribution of its common on common stock was a dividend which is not includible in equity invested capital as a distribution in stock which comes within section 718 (a) (3) (A), Internal Revenue Code. Owensboro…
2Cases cited6 opinions
- Stern Bros. & Co. v. CommissionerUnited States Tax Court · 1951
- Lester Lumber Co. v. CommissionerUnited States Tax Court · 1950
- Owensboro Wagon Co. v. CommissionerUnited States Tax Court · 1952
- Prosper Shevenell & Son, Inc. v. CommissionerUnited States Tax Court · 1945
- F. Brody & Sons Co. v. CommissionerUnited States Tax Court · 1948
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