Legal Opinion

McRitchie v. Commissioner

United States Tax Court

Decided October 19, 1956No. Docket No. 56936Published

As a result of a controversy in which title to shares of stock standing in the name of Lee McRitchie was contested by another, the corporation withheld dividends declared in 1948. In 1949 it instituted an interpleader action and paid into the registry of the court the 1948 and 1949 dividends. In 1950 it similarly deposited the dividends declared during that year.

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As a result of a controversy in which title to shares of stock standing in the name of Lee McRitchie was contested by another, the corporation withheld dividends declared in 1948. In 1949 it instituted an interpleader action and paid into the registry of the court the 1948 and 1949 dividends. In 1950 it similarly deposited the dividends declared during that year. The litigation finally terminated in McRitchie's favor in 1951 when the funds in the hands of the court were released to him. Held, the dividends were income to petitioners in 1951, and were not chargeable to the corporation in 1948…

1Opinion of the Court

Lee McRitchie and Agnes McRitchie, Petitioners, v. Commissioner of Internal Revenue, Respondent

McRitchie v. Commissioner

Docket No. 56936

United States Tax Court

27 T.C. 65; 1956 U.S. Tax Ct. LEXIS 66;

October 19, 1956, Filed

Decision will be entered for the respondent.

As a result of a controversy in which title to shares of stock standing in the name of Lee McRitchie was contested by another, the corporation withheld dividends declared in 1948. In 1949 it instituted an interpleader action and paid into the registry of the court the 1948 and 1949 dividends. In 1950 it similarly deposited the…

2Cases cited20 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Hart v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1932
  3. Petit v. CommissionerUnited States Tax Court · 1947
  4. Commissioner of Internal Revenue v. OwensCourt of Appeals for the Tenth Circuit · 1935
  5. E. T. Slider, Inc. v. CommissionerUnited States Tax Court · 1945

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