Senior Inv. Corp. v. Commissioner
United States Tax Court
1. Where the provisions of an amendment to the charter of petitioner and certificates of stock issued thereunder prohibited the payment of dividends until the earnings and profits of petitioner should accumulate and be transferred in a certain amount to capital or capital surplus to wipe out a deficit, and such earnings and profits had not been accumulated in such amount in any of the taxable years, held that petitioner is not entitled to credits by reason of such provisions…
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1. Where the provisions of an amendment to the charter of petitioner and certificates of stock issued thereunder prohibited the payment of dividends until the earnings and profits of petitioner should accumulate and be transferred in a certain amount to capital or capital surplus to wipe out a deficit, and such earnings and profits had not been accumulated in such amount in any of the taxable years, held that petitioner is not entitled to credits by reason of such provisions of its charter and certificates of stock in any of those years under section 26 (c) (1) of the Revenue Act of 1936;…
1Opinion of the Court
Senior Investment Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Senior Inv. Corp. v. Commissioner
Docket No. 104631
United States Tax Court
2 T.C. 124; 1943 U.S. Tax Ct. LEXIS 140;
June 15, 1943, Promulgated
Decision will be entered under Rule 50, except that in so far as the proceeding pertains to personal holding company surtax for the year 1936 an order will be entered dismissing the proceeding for want of jurisdiction.
1. Where the provisions of an amendment to the charter of petitioner and certificates of stock issued thereunder prohibited the payment of dividends…
2Cases cited15 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Lynch v. HornbySupreme Court of the United States · 1918
- Willcuts v. Milton Dairy Co.Supreme Court of the United States · 1927
- Mobile & Ohio Railroad v. TennesseeSupreme Court of the United States · 1894
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