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Taxation - Income Taxation Of Stock Dividends, Donald H. Larmee
Taxation - Income Taxation Of Stock Dividends, Donald H. Larmee
Michigan Law Review
The petitioner purchased cumulative non-voting preferred stock in a corporation. In subsequent years the company elected to pay, and the petitioner received, dividends in common voting stock. Later the company redeemed its preferred stock. In computing the profit made by the petitioner at the time of redemption, the commissioner allocated to the common stock a proportionate share of the original cost of the preferred stock. He thereupon taxed as income the difference between the redemption figure and the allocated portion of the cost. The stockholder protested, claiming that the stock dividends should be treated as income in the years in …
Taxation-Validity Of Tax On Income Of Superintendent Of School Cafeteria System -Sovereign Immunity, Elbridge D. Phelps
Taxation-Validity Of Tax On Income Of Superintendent Of School Cafeteria System -Sovereign Immunity, Elbridge D. Phelps
Michigan Law Review
Petitioners, husband and wife, residents of Texas, made returns of community income for the year 1932, listing as exempt the salary of the wife who was superintendent of a non-profit cafeteria system operated by the Ft. Worth public schools for the exclusive patronage and benefit of teachers and students. The Commissioner of Internal Revenue refused the exemption and levied a deficiency tax of $105. On appeal from an affirmance of the commissioner's decision by the Board of Tax Appeals, held, reversed on the ground that the operation of the cafeteria system was a proper exercise of a governmental function …