Century Electric Co. v. Commissioner
United States Tax Court
For the period from March 1, 1913, to December 31, 1935, the petitioner's earnings and profits were substantially in excess of the cash dividends paid. On its books, such excess of earnings and profits were capitalized through the payment of stock dividends of common stock on common stock.
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For the period from March 1, 1913, to December 31, 1935, the petitioner's earnings and profits were substantially in excess of the cash dividends paid. On its books, such excess of earnings and profits were capitalized through the payment of stock dividends of common stock on common stock. Held, that the payment of the stock dividends did not effect a distribution of petitioner's earnings and profits, see section 115 (h) of the Revenue Act of 1936, and that the petitioner at December 31, 1935, and at December 31, 1936, did not have a deficit in accumulated earnings and profits and is not…
1Opinion of the Court
Century Electric Company, a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Century Electric Co. v. Commissioner
Docket No. 108667
United States Tax Court
3 T.C. 297; 1944 U.S. Tax Ct. LEXIS 191;
February 18, 1944, Promulgated
Decision will be entered for the respondent.
For the period from March 1, 1913, to December 31, 1935, the petitioner's earnings and profits were substantially in excess of the cash dividends paid. On its books, such excess of earnings and profits were capitalized through the payment of stock dividends of common stock on common stock. Held, that the…
2Cases cited13 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Koshland v. HelveringSupreme Court of the United States · 1936
- White v. United StatesSupreme Court of the United States · 1938
- Helvering v. GriffithsSupreme Court of the United States · 1943
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