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Estate of Putnam Vs. Commissioner
Cites for this judgment
- US Supreme Court
- Mar 26, 1945
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U.S. 393 (1945) U.S. Supreme Court Estate of Putnam v. CommissionerSearch
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U.S. 393 (1945) Estate of Putnam v. CommissionerSearch
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because of a conflict in conclusion Page 324 U. S. 395 between Tar Products Corp. v. CommissionerSearch
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below and those in other circuits as to whether the governing rule is to be drawn from federal or state law. Helvering v. McGlue'sSearch
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Commissioner v. CohenSearch
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law controlled the disposition of the controversy, and that the dividend accrued on its declaration. Commissioner v. GuarantySearch
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should be uniform unless Congress has shown an intention to permit its meaning to be varied by state law. Burnet v. HarmelSearch
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U. S. 396 of that test is a federal responsibility. The present problem is closely akin to that resolved in Lyeth v. HoeySearch
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We recently examined the Congressional purpose in the enactment of Section 42. Helvering v. Enright'sSearch
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as cash was not income to the estate. Helvering v. Enright'sSearch
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United States v. AndersonSearch
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declaration of a dividend with a subsequent record date for payment would not affect the stock's value. United States v. PhellisSearch
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Ford v. SnookSearch
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Beattie v. GedneySearch
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Western Securities Co. v. SilverSearch
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Smith v. TaeckerSearch
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Richter & Co. v. LightSearch
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Nutter v. AndrewsSearch
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accrual date under Section 42 is held eventually to be the same for taxpayers on the accrued and cash basis. Cf. Avery v. CommissionerSearch
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Tar Products Corp. v. CommissionerSearch
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in cash by the estate was merely a conversion into money of one of the assets of the estate, citing Vanderbilt v. CommissionerSearch
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Nichols v. UnitedSearch
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United States v. PhellisSearch
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to the taxpayer's method of accounting, which is directed in Sec. 48(c), 52 Stat. 476, is not of use. Helvering v. Enright'sSearch
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dividends, as it is in the section of the statute here involved. This rule has been continuously applied. See Mason v. RoutzahnSearch
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Mertens, Federal Income Taxation, 17. See Tar Products Corp. v. CommissionerSearch
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of position of those regulations as to date when dividends are received by a taxpayer. American Light & Traction Co. v. CommissionerSearch
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This accords with the original holding of the Board of Tax Appeals on this question in Estate of McGlue v. CommissionerSearch
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B.T.A. 1186, 1193. After that case was reversed on the law of New York, Helvering v. McGlue'sSearch
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Estate, 119 F.2d 167, the Board followed the Circuit Court decision. Estate of Ledyard v. CommissionerSearch
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held that a taxpayer on the accrual basis should account for a dividend when received. American Light & Traction Co. v. CommissionerSearch
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U.S. Supreme Court Estate of Putnam v. CommissionerSearch
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Helvering v. McGlue'sSearch
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Commissioner v. GuarantySearch
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Helvering v. Enright'sSearch
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Cf. Avery v. CommissionerSearch
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Vanderbilt v. CommissionerSearch
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See Mason v. RoutzahnSearch
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See Tar Products Corp. v. CommissionerSearch
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American Light & Traction Co. v. CommissionerSearch
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Estate of McGlue v. CommissionerSearch
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of New York, Helvering v. McGlue'sSearch
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