Darrow v. Commissioner
United States Tax Court
Rendar paid no dividends during its 1968 fiscal taxable year but paid a dividend, adequate in amount to exhaust its "undistributed personal holding company income," before the 15th day of the third month following the close of such year.
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Rendar paid no dividends during its 1968 fiscal taxable year but paid a dividend, adequate in amount to exhaust its "undistributed personal holding company income," before the 15th day of the third month following the close of such year. Held: Even assuming that Rendar had reasonable cause for failing to pay any dividends during its 1968 fiscal year, such reasonable cause is no defense to its failure to comply with sec. 563(b), which requires that some dividends must have actually been paid during its 1968 fiscal year. It is therefore liable for the 70-percent personal holding company tax as…
1Opinion of the Court
Kenneth Farmer Darrow, Trustee for the Creditors and Shareholders of Rendar Enterprises, Ltd., a Dissolved Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Darrow v. Commissioner
Docket No. 8144-71
United States Tax Court
64 T.C. 217; 1975 U.S. Tax Ct. LEXIS 149;
May 14, 1975, Filed
Decision will be entered for the respondent.
Rendar paid no dividends during its 1968 fiscal taxable year but paid a dividend, adequate in amount to exhaust its "undistributed personal holding company income," before the 15th day of the third month following the close of such year. Held: Even…
2Cases cited18 opinions
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Sicanoff Vegetable Oil Corp. v. CommissionerUnited States Tax Court · 1957
- O'Sullivan Rubber Co. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1941
- Sicanoff Vegetable Oil Corporation v. Commissioner of Internal Revenue, Sicanoff Tallow Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
- Frelbro Corp. v. CommissionerUnited States Tax Court · 1961
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