Singleton v. Commissioner of Internal Revenue

439 U.S. 940 (1978)

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Singleton v. Commissioner of Internal Revenue

United States Supreme Court
439 U.S. 940 (1978)

Facts

Singleton (plaintiff) received a cash distribution for shares of stock he owned in a corporation. The tax court held that the distribution was a return of capital and not taxable. The United States Court of Appeals for the Fifth Circuit held that the distribution was taxable as a dividend. Singleton filed a petition for a writ of certiorari in the United States Supreme Court. The United States Supreme Court denied the petition for a writ of certiorari.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

Dissent (Blackmun, J.)

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