Citizens Federal Sav. & Loan Ass'n v. Commissioner
United States Tax Court
Respondent determined that petitioner, a Federal savings and loan association, was not entitled to deduct in 1952, the first year in which it was subject to the corporate income tax, dividends declared on its net earnings for the 6-months' period ended December 31, 1951. Held, on the facts, dividends credited to petitioner's "savings account" shareholders as of December 31, 1951, were not deductible by petitioner in 1952. Held, further, since the dividends payable by…
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Respondent determined that petitioner, a Federal savings and loan association, was not entitled to deduct in 1952, the first year in which it was subject to the corporate income tax, dividends declared on its net earnings for the 6-months' period ended December 31, 1951. Held, on the facts, dividends credited to petitioner's "savings account" shareholders as of December 31, 1951, were not deductible by petitioner in 1952. Held, further, since the dividends payable by petitioner to its "investment" shareholders for the period ended December 31, 1951, were paid by checks dated January 2, 1952,…
1Opinion of the Court
Citizens Federal Savings and Loan Association of Covington, Petitioner, v. Commissioner of Internal Revenue, Respondent
Citizens Federal Sav. & Loan Ass'n v. Commissioner
Docket No. 63099
United States Tax Court
30 T.C. 285; 1958 U.S. Tax Ct. LEXIS 192;
May 15, 1958, Filed
Decision will be entered under Rule 50.
Respondent determined that petitioner, a Federal savings and loan association, was not entitled to deduct in 1952, the first year in which it was subject to the corporate income tax, dividends declared on its net earnings for the 6-months' period ended December 31, 1951. Held, on the facts,…
2Cases cited11 opinions
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Avery v. CommissionerSupreme Court of the United States · 1934
- National Airlines, Inc. v. CommissionerUnited States Tax Court · 1947
- Gulf Power Co. v. CommissionerUnited States Tax Court · 1948
- Jenkins v. BitgoodCourt of Appeals for the Second Circuit · 1939
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