Legal Opinion

Atlas Tack Co. v. Commissioner

United States Board of Tax Appeals

Decided May 18, 1928No. Docket No. 11497Published

1. Dividend paid by petitioner during the taxable year held to have been paid from current earnings. 2. Where earnings of the current year to the date of payment of a dividend may not be accurately determined, the earnings of the entire year may be prorated. 3. Petitioner held not entitled to have its profits tax computed under the provisions of section 328, Revenue Act of 1918.

1Opinion of the Court

ATLAS TACK CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Atlas Tack Co. v. Commissioner

Docket No. 11497.

United States Board of Tax Appeals

12 B.T.A. 3; 1928 BTA LEXIS 3617;

May 18, 1928, Promulgated

1. Dividend paid by petitioner during the taxable year held to have been paid from current earnings.

2. Where earnings of the current year to the date of payment of a dividend may not be accurately determined, the earnings of the entire year may be prorated.

3. Petitioner held not entitled to have its profits tax computed under the provisions of section 328, Revenue Act of 1918.

W. E.…

2Cases cited5 opinions

  1. Edwards v. DouglasSupreme Court of the United States · 1925
  2. Mason v. RoutzahnSupreme Court of the United States · 1927
  3. L. S. Ayers & Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  4. Atlas Tack Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  5. Atlas Tack Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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