Atlantic Land Co. v. Commissioner
United States Board of Tax Appeals
Dividend, less in amount than the corporation's earned surplus and less than the value of unencumbered stocks and bonds available for payment of dividends, was declared in December 1936. The dividend was credited to the stockholders upon the corporation's books, without restriction as to withdrawal, and the stockholders had notice. They reported the dividend in income tax returns for 1936 and paid income tax thereon.
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Dividend, less in amount than the corporation's earned surplus and less than the value of unencumbered stocks and bonds available for payment of dividends, was declared in December 1936. The dividend was credited to the stockholders upon the corporation's books, without restriction as to withdrawal, and the stockholders had notice. They reported the dividend in income tax returns for 1936 and paid income tax thereon. The accounts payable representing the dividends were paid to the stockholders in January, February, and March 1937. Held, that the corporation was entitled to credit for a…
1Opinion of the Court
OPINION.
Disney :
This proceeding involves income tax for the calendar year 1936 in the amount of $3,129.65, in which amount deficiency was determined by the Commissioner. All facts were stipulated and we find the facts as so stipulated. They may, so far as necessary to the examination of the question involved, be summarized as follows:
The petitioner is a corporation organized under the law of Pennsylvania, has its principal office in Pennsylvania, and filed its income *75tax return for 1936 with the collector of the twenty-third district of Pennsylvania.
The deficiency of $3,129.65 resulted from…
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