Legal Opinion

Graham v. Commissioner

United States Board of Tax Appeals

Decided June 8, 1932No. Docket Nos. 38335-38337, 38349-38351Published

1. Receipt of assets belonging to a taxpayer by a trustee in liquidation does not establish individual transferee liability. 2. Stockholders of a corporation received a dividend of $700 per share at a date when the corporation was solvent and such distribution did not result in insolvency.

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1. Receipt of assets belonging to a taxpayer by a trustee in liquidation does not establish individual transferee liability. 2. Stockholders of a corporation received a dividend of $700 per share at a date when the corporation was solvent and such distribution did not result in insolvency. Held, that the stockholders are not liable under section 280 of the Revenue Act of 1926 for income taxes due from the corporation. 3. The statutory liability of California corporation stockholders is not such a liability as may be asserted under section 280 of the Revenue Act of 1926.

1Opinion of the Court

M. H. GRAHAM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

ESTATE OF H. C. STONE, MRS. H. C. STONE, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

G. H. MOORE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

H. C. CHENOWITH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

ESTATE OF W. L. HODGES, AGNES WILEY HODGES, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

W. L. HODGES, TRUSTEE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Graham v. Commissioner

Docket Nos. 38335-38337, 38349-38351.

United…

2Cases cited8 opinions

  1. McDonald v. WilliamsSupreme Court of the United States · 1899
  2. Keller v. CommissionerUnited States Board of Tax Appeals · 1930
  3. Gould v. CommissionerUnited States Board of Tax Appeals · 1930
  4. Southern Cal. Rock & Gravel Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Kinnett-Odom Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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