Add to ORKGTaxpayer, a corporate shareholder, received from the corporation a distribution of property which had appreciated in value over its adjusted cost. The earnings and profits of the corporation were sufficient to cover the adjusted cost of the property distributed, but were not sufficient to cover its full fair market value at the time of distribution. The Tax Court held that the fair market value of the distribution was taxable as a dividend only to the extent of the corporation\u27s earnings and profits. On appeal, held, reversed. In determining whether a distribution in kind is a dividend under section 115(a), the earnings and profits of the corporation are to be charged with the adjusted basis of the property distributed, without regard to...
In 1942 plaintiff employer adopted a profit-sharing plan under which a percentage of each year\u27s ...
Petitioner, E. P. Coady, and M. Christopher each owned 50 percent of the stock of the Christopher Co...
Petitioner owned more than three-fourths of the stock in a corporation whose shares had a par value ...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
Plaintiff corporation set up a profit sharing trust for the benefit of its employees as authorized u...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
A corporation took out several policies of insurance on the life of its president, naming itself as ...
In ASARCO, Inc. v. Idaho State Tax Commission, the Supreme Court rejected Idaho’s definition of inco...
A corporation charged off notes as worthless prior to 1942. Anticipating future collections on the n...
In 1948 petitioner and several other taxpayers, who had previously been active in constructing homes...
P and B owned all the outstanding shares of X Corporation. In 1937 P purchased B\u27s shares and gav...
In 1864 the Joliet and Chicago Railroad Company made a perpetual lease without a defeasance clause o...
In 1942 plaintiff employer adopted a profit-sharing plan under which a percentage of each year\u27s ...
Petitioner, E. P. Coady, and M. Christopher each owned 50 percent of the stock of the Christopher Co...
Petitioner owned more than three-fourths of the stock in a corporation whose shares had a par value ...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
Plaintiff corporation set up a profit sharing trust for the benefit of its employees as authorized u...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
A corporation took out several policies of insurance on the life of its president, naming itself as ...
In ASARCO, Inc. v. Idaho State Tax Commission, the Supreme Court rejected Idaho’s definition of inco...
A corporation charged off notes as worthless prior to 1942. Anticipating future collections on the n...
In 1948 petitioner and several other taxpayers, who had previously been active in constructing homes...
P and B owned all the outstanding shares of X Corporation. In 1937 P purchased B\u27s shares and gav...
In 1864 the Joliet and Chicago Railroad Company made a perpetual lease without a defeasance clause o...
In 1942 plaintiff employer adopted a profit-sharing plan under which a percentage of each year\u27s ...
Petitioner, E. P. Coady, and M. Christopher each owned 50 percent of the stock of the Christopher Co...
Petitioner owned more than three-fourths of the stock in a corporation whose shares had a par value ...