Stranahan v. Commissioner
United States Board of Tax Appeals
1. Dividends paid in 1917 are taxable at 1917 rates to the extent of 1917 earnings available for distribution at the time of the declaration of the dividend. Edwards v. Douglas,269 U.S. 204; 46 Sup.Ct. 85; 5 Am.Fed. Tax Rep. 5666. 2. Commissioner's finding by pro rata method that one-sixth of 1917 earnings was available for distribution on March 1, 1917, approved. Douglas v. Edwards,287 Fed. 919; 2 Am. Fed. Tax Rep. 1890.
1Opinion of the Court
*1144OPINION.
Arundell:
If there was any doubt at the time of filing these appeals as to our jurisdiction to hear and determine them, it has been *1145removed by section 288(f) of the Revenue Act of 1926, which provides in part:
If any deficiency in any income, war-profits, or excess-profits tax imposed by the Revenue Act of 1916, the Revenue Act of 1917, the Revenue Act of 1918, or the Revenue Act of 1921, or by any such Act as amended, was assessed before June 3, 1924, but was not paid in full before that date, and if the Commissioner after June 2, 1924, but before the enactment of this Act finally…
2Cases cited3 opinions
- Edwards v. DouglasSupreme Court of the United States · 1925
- Douglas v. EdwardsCourt of Appeals for the Second Circuit · 1924
- Douglas v. EdwardsDistrict Court, S.D. New York · 1922
3Cited by1 opinion
- Stranahan v. CommissionerUnited States Board of Tax Appeals · 1926