Legal Opinion

Bayard v. Commissioner

United States Board of Tax Appeals

Decided October 7, 1938No. Docket No. 59550Published

During the period August 1, 1927, to December 31, 1928, petitioner had outstanding 100,000 shares of class B voting common stock, which was unlimited and nonpreferred as to dividends. During the same period it also had outstanding 100,000 shares of class A common stock, more than 95 percent of which was owned by the Associated Gas & Electric Co. or one of its affiliates.

Read the full summary

During the period August 1, 1927, to December 31, 1928, petitioner had outstanding 100,000 shares of class B voting common stock, which was unlimited and nonpreferred as to dividends. During the same period it also had outstanding 100,000 shares of class A common stock, more than 95 percent of which was owned by the Associated Gas & Electric Co. or one of its affiliates. On July 25, 1927, the latter company entered into a written agreement with a Massachusetts trust, with which it was not affiliated, wherein it was agreed that the trust would be permitted to subscribe for and purchase…

1Opinion of the Court

THOMAS F. BAYARD, TRUSTEE OF THE EASTERN UTILITIES INVESTING CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Bayard v. Commissioner

Docket No. 59550.

United States Board of Tax Appeals

38 B.T.A. 778; 1938 BTA LEXIS 828;

October 7, 1938, Promulgated

During the period August 1, 1927, to December 31, 1928, petitioner had outstanding 100,000 shares of class B voting common stock, which was unlimited and nonpreferred as to dividends. During the same period it also had outstanding 100,000 shares of class A common stock, more than 95 percent of which was owned by the Associated…

2Cases cited14 opinions

  1. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  2. Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
  3. Helvering v. Morgan's, Inc.Supreme Court of the United States · 1934
  4. Helvering v. Midland Mutual Life InsuranceSupreme Court of the United States · 1937
  5. Handy & Harman v. BurnetSupreme Court of the United States · 1931

9 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API