Iverson v. Commissioner
United States Board of Tax Appeals
1. During the taxable year a corporation of which I. C. Iverson was the sole stockholder made certain payments. Part of these were made directly to him and part of them were made to a bank, but all of them were applied toward the payment of the purchase price of certain stock in the corporation which Iverson had acquired from a former stockholder.
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1. During the taxable year a corporation of which I. C. Iverson was the sole stockholder made certain payments. Part of these were made directly to him and part of them were made to a bank, but all of them were applied toward the payment of the purchase price of certain stock in the corporation which Iverson had acquired from a former stockholder. Held, that under the circumstances here presented such payments constituted taxable dividends. 2. Respondent's determination of penalty not sustained.
1Opinion of the Court
*867OPINION.
TeaMmell :
The only assignment of error contained in the petitions is as f ollo-ws:
Tlie Commissioner has erroneously included in gross income — as dividends received from a domestic corporation — moneys paid to one William W. Wood for tbe purchase by the said corporation of stock owned by the said William W. Wood.
In support of their position the petitioners contend that it was the intention of Wood and Iverson in entering into the agreement of May 19,1925, to liquidate one half of all the property of the corporation and to make payment of the value thereof to Wood. They also urge that…
2Cases cited5 opinions
- Kom v. Cody Detective Agency, Inc.Washington Supreme Court · 1913
- L. J. Christopher Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- State Ex Rel. Howland v. Olympia Veneer Co.Washington Supreme Court · 1926
- Hunt v. CommissionerUnited States Board of Tax Appeals · 1927
- Max M. Barken Drug Co. v. CommissionerUnited States Board of Tax Appeals · 1926
3Cited by10 opinions
- Sachs v. CommissionerUnited States Tax Court · 1959
- Deutsch v. CommissionerUnited States Tax Court · 1962
- Berlin v. CommissionerUnited States Tax Court · 1961
- Bibb v. CommissionerUnited States Tax Court · 1965
- Bruckheimer v. CommissionerUnited States Board of Tax Appeals · 1942
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