Valley Lumber Co. v. Commissioner
United States Board of Tax Appeals
Dividends declared and credited to the accounts of shareholders, subject to their demand and control, but not withdrawn, held, dividends paid, for the purpose of the credit under section 27, Revenue Act of 1936.
1Opinion of the Court
OPINION.
Steknhagen:
The Commissioner determined a deficiency for 1936 of $967.36 in income tax and $28.36 in excess profits tax. He disallowed a dividends paid credit of so much of the amounts of dividends declared and credited to shareholders’ accounts as was not withdrawn by them. The facts are found as stipulated.
*424The petitioner was a close corporation, with eight shareholders. Its accounts and return were on an accrual basis. In 1936 it declared two dividends, one on September 5 and the other on December 24, both payable at once. All the shareholders had accounts on the corporation’s books…
2Cases cited3 opinions
- Avery v. CommissionerSupreme Court of the United States · 1934
- Massachusetts Mutual Life Insurance v. United StatesSupreme Court of the United States · 1933
- In re Interborough Consol. Corp.Court of Appeals for the Second Circuit · 1923
3Cited by9 opinions
- Bush Bros. & Co. v. CommissionerUnited States Tax Court · 1979
- Parks-Chambers, Inc. v. CommissionerUnited States Board of Tax Appeals · 1942
- International Bedaux Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
- Royal Mfg. Co. v. CommissionerCourt of Appeals for the Third Circuit · 1943
- Bay Ridge Operating Co. v. CommissionerUnited States Tax Court · 1970
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