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Ferguson v. Commissioner
United States Tax Court
47 T.C. 11 (1966)
- Written by Heather Ryfa, JD
Facts
Joseph Ferguson (plaintiff) received $75,000 from a corporation named 444, of which he was the sole shareholder. The commissioner of Internal Revenue (defendant) characterized the payment as a constructive dividend. Ferguson appealed the assessment to the United States Tax Court, contending that 444 did not have sufficient earnings and profits to pay the dividend once the current year’s corporate income tax liability was deducted. The commissioner responded that such a deduction was improper because the corporation, which used the cash method of accounting, had not paid the tax liability in the tax year at issue.
Rule of Law
Issue
Holding and Reasoning (Hoyt, J.)
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