Farmers' Union Co-Op. Ass'n v. Commissioner

*970OPINION.

Lansdon:

The single contention of the petitioner herein is that under its by-laws the provisions of which were authorized by the law of Nebraska, the amount of $6,263.85 was a liability to its patrons at May 31, 1920. The respondent denies that any liability was accrued or accruable at May 31, 1920, and asserts that if such liability for the payment of the amount in controversy ever existed it was incurred by the action of the annual stockholders’ meeting on June 19. lie further contends that if any dividend, patronage or otherwise, was declared, it was a stock dividend and had no…