Opinion

Chaplin v. Commissioner

  • 46 B.T.A. 385
  • 1942 BTA LEXIS 872
Court
United States Board of Tax Appeals
Filed
Feb 24, 1942
Status
Published
Author
Leech
On the bench
Sternhagen, Leech, Mellott
Cited by
0 cases

The opinion

Leech,

dissenting: I think the two basic holdings in the majority opinion, expressed in the headnote, are inconsistent with each other and are both wrong. In my judgment, the stock in United Artists Corporation was intended to be and was received by the petitioner in 1919 when it was issued in the name of petitioner and delivered to the escrow agent. The stock was held by the escrow agent merely to guarantee performance of petitioner’s contract to deliver pictures. The dividends declared and paid on this stock were taxable to petitioner as such when received by the escrow agent. See Bonham v. Commissioner, 89 Fed. (2d) 725, affirming 33 B. T. A. 1100.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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