Columbia River Paper Mills v. Commissioner
United States Board of Tax Appeals
By the provisions of a written contract executed prior to May 1, 1936, the petitioner was prevented from paying any "cash" dividends out of its profits for 1936. Since in the circumstances of this case any dividends paid by the petitioner in 1936 would of necessity have had to be paid in cash, it is held, that the petitioner is entitled under section 26(c) of the Revenue Act of 1936 to a credit equaling the amount of its adjusted net income.
1Opinion of the Court
*264OPINION.
Smith:
This is a proceeding for the redetermination of a deficiency in income tax for 1936 of $4,195.50. The petitioner alleges that in the determination of the deficiency the respondent erred in failing to allow it a credit under the provisions of section 26 (c) of the Revenue Act of 1936 of the full amount of its adjusted net income for that year.
This proceeding has been submitted to the Board upon the basis of the pleadings, a signed stipulation of facts (incorporated herein by reference), and seven exhibits. They may be briefly summarized as follows:
The petitioner is a corporation…
2Cited by6 opinions
- Commissioner v. Columbia River Paper MillsCourt of Appeals for the Ninth Circuit · 1942
- Columbia River Paper Mills v. CommissionerUnited States Board of Tax Appeals · 1941
- E. C. Atkins & Co. v. CommissionerUnited States Board of Tax Appeals · 1941
- Helms Bakeries v. CommissionerUnited States Board of Tax Appeals · 1942
- Northwest Bancorporation v. CommissionerUnited States Tax Court · 1943
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