Stern v. Commissioner
United States Board of Tax Appeals
1. A stock dividend of 5 percent cumulative preferred stock paid to holders of common stock, the only outstanding class of stock, is taxable under the Revenue Act of 1936. 2. The preferred stock was issued on June 1, 1936. With respect to such dividends, Held, the Revenue Act of 1936 was retroactively effective from January 1, 1936. 3. Held, that the issuing corporation had accumulated and current earnings and profits sufficient to pay such stock dividend.
1Opinion of the Court
ALFRED E. STERN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
IRVIN STERN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
FANNY C. HOLZHEIMER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Stern v. Commissioner
Docket Nos. 105438, 105439, 105440.
United States Board of Tax Appeals
46 B.T.A. 416; 1942 BTA LEXIS 874;
February 24, 1942, Promulgated
1. A stock dividend of 5 percent cumulative preferred stock paid to holders of common stock, the only outstanding class of stock, is taxable under the Revenue Act of 1936.
2. The preferred stock was issued on June…
2Cases cited10 opinions
- Welch v. HenrySupreme Court of the United States · 1938
- Koshland v. HelveringSupreme Court of the United States · 1936
- Milliken v. United StatesSupreme Court of the United States · 1931
- United States v. HudsonSupreme Court of the United States · 1937
- Kelly v. CommissionerUnited States Board of Tax Appeals · 1938
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