Dean v. Commissioner
United States Tax Court
1. Dean was the sole stockholder of Warrington, a corporation engaged in the business of developing residential subdivisions in the Pensacola-Fort Walton area of Florida. The houses constructed were sold on the open market. FHA and VA, upon which Warrington depended for its financing, required that the houses be serviced by water and sewer facilities approved by the State Board of Health.
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1. Dean was the sole stockholder of Warrington, a corporation engaged in the business of developing residential subdivisions in the Pensacola-Fort Walton area of Florida. The houses constructed were sold on the open market. FHA and VA, upon which Warrington depended for its financing, required that the houses be serviced by water and sewer facilities approved by the State Board of Health. After building a number of houses with septic tanks and a number through use of the facilities of a private utility, Warrington was compelled to build its own sewer facilities to service its Garnier Beach…
1Opinion of the Court
BRUoe, Judge:
Respondent determined deficiencies in the income taxes of petitioners for the years and in the amounts as follows:
Year Deficiency
1962 -$14,005.34
1963 - 11,286.70
1964 - 183, 940.00
Concessions have been made by both parties and the issues remaining for decision are: (1) Did petitioners receive a dividend distribution as the result of the transfer of certain sewer facilities by Warrington Home Builders during 1964? (2) Did advances made to Walter K. Dean constitute taxable dividends to the petitioners during the years 1962 and 1963 in the amounts of $16,085.10 and $1,014.21,…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. HorstSupreme Court of the United States · 1940
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- Helvering v. Midland Mutual Life InsuranceSupreme Court of the United States · 1937
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3Cited by53 opinions
- Charles A. Sammons, Individually, and Estate of Rosine S. Sammons, Deceased, Charles A. Sammons, Independent v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
- Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
- James and Martha Kuper and Charles and Kathleen Kuper, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Fifth Circuit · 1976
- Rapid Electric Co. v. CommissionerUnited States Tax Court · 1973
- Smith v. CommissionerUnited States Tax Court · 1978
48 more not listed; retrieve them via the Exa API.