Daggitt v. Commissioner
United States Tax Court
Stock distributed to two stockholders substantially in proportion to their prior stock ownership, purportedly in payment of salary, held, not to constitute taxable income.
1Opinion of the Court
OPINION.
Raum, Judge:
The Commissioner of Internal Revenue determined deficiencies in income tax for 1948 in the amount of $17,193.40 against Deloss E. and Duana C. Daggitt, and in the amount of $910.92 against Joseph and Mae Reid. The petitioners in each case are husband and wife, residing in Michigan, and the joint returns in question for 1948 were filed with the then collector of internal revenue at Detroit, Michigan. Substantially all of the facts have been established by admissions in the pleadings and by a stipulation of facts with accompanying joint exhibits. All such facts are…
2Cases cited4 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Helvering v. GriffithsSupreme Court of the United States · 1943
- Helvering v. SprouseSupreme Court of the United States · 1943
- Messer v. CommissionerUnited States Tax Court · 1953
3Cited by10 opinions
- Putoma Corp. v. CommissionerUnited States Tax Court · 1976
- Commissioner v. Fender Sales, Inc.Court of Appeals for the Ninth Circuit · 1964
- James Marquis Hedrick v. United StatesCourt of Appeals for the Tenth Circuit · 1966
- Joy Mfg. Co. v. CommissionerUnited States Tax Court · 1955
- Commissioner of Internal Revenue v. Fender Sales, Inc., Commissioner of Internal Revenue v. Donald D. And Jean Randall, Commissioner of Internal Revenue v. Esther Fender, Commissioner of Internal Revenue v. Jean E. Randall, Commissioner of Internal Revenue v. Donald D. Randall, Commissioner of Internal Revenue v. E. Leo FenderCourt of Appeals for the Ninth Circuit · 1965
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