MATUSOW

v.

UNITED STATES

Citator

Cited By (15 total)

• United States v. Fewell, 255 F.2d 496 (5th Cir. 1958)
  …, supra; Smith v. United States, supra; Boyle v. Commissioner, supra; Ferro v. Commissioner, supra; Kessner v. Commissioner, supra; Commissioner of Internal Revenue v. Sullivan, supra; Earle v. Woodlaw, 9 Cir., 1957, 245 F. 2d 119, certiorari denied 354 U.S. 942, 77 S.Ct. 1400, 1 L.Ed.2d 1537; Commissioner of Internal Revenue v. Snite, supra; Pacific Vegetable Oil Corp. v. Commissioner, supra; Jones v. Griffin, supra. . Flanagan v. Helvering, supra; Hawkinson v. Commissioner, 2 Cir., 1956, 235 F. 2d 747; F…
• Genevra Heman v. Commissioner OF Internal Revenue, 283 F.2d 227 (8th Cir. 1960)
  …gnificance of dividends paid in the past; was there a sufficient accumulation of earned surplus to cover the distribution, or was it partly from capital. Flanagan v. Helvering, supra; Earle v. Woodlaw, (C.A. 9, 1957) 245 F. 2d 119, certiorari denied 354 U.S. 942.” 32 T.C. 479, 486-487. Petitioners agree with the statement made by the Tax Court to the effect that the essentially equivalent test presents a fact issue. Petitioners do not challenge the criteria to be used as guideposts as specified by the Tax…
• United States v. Gerald and Gladys Carey, 289 F.2d 531 (8th Cir. 1961)
  …nificance of dividends paid in the past; was there a sufficient accumulation of earned surplus to cover the distribution, or was it partly from capital. Flanagan v. Helvering, supra; Earle v. Woodlaw. (C. A. 9, 1957) 245 F. 2d 119; certiorari denied 354 U.S. 942 [77 S.Ct. 1400,1 L.Ed.2d 1537].” 32 T.C. 479, 486-487. There is no single or conclusive test of whether partial liquidation distribution is essentially equivalent to a dividend. The net effect of the transaction is at least an important considerati…