Journal Co. v. Commissioner

1. In 1937 petitioner issued and distributed as dividends notes of a fair market value equal to the face thereof, due January 1, 1939. It claimed and was allowed a dividends paid credit in 1937 on the aggregate amount of the notes. On July 1, 1938, petitioner paid and discharged the notes and claimed a dividends paid credit under section 27(a)(4), Revenue Act of 1938. Held, the general provisions of section 27(a)(4) are limited by the specific provisions of section 27(e), and petitioner is not entitled to a dividends paid credit in the amount paid in discharge of the notes. Spokane Dry Goods…