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Wagner v. Comm'r

3 Cited authorities

  1. Eisner v. Macomber

    252 U.S. 189 (1920)   Cited 733 times   10 Legal Analyses
    Holding that income is not realized unless it “is available for actual distribution”

  2. Southern Pacific Co. v. Lowe

    247 U.S. 330 (1918)   Cited 163 times
    In Southern Pacific Co. v. Lowe, 247 U.S. 330, at page 335, 38 S. Ct. 540, 542, 62 L. Ed. 1142, the court said: "We are bound to consider accumulations that accrued to a corporation prior to January 1, 1913, as being capital, not income, for the purposes of the act.

  3. Gulf Oil Corp. v. Lewellyn

    248 U.S. 71 (1918)   Cited 81 times
    In Gulf Oil Corporation v. Lewellyn, 248 U.S. 71, 39 S. Ct. 35, 63 L. Ed. 133, it was held that dividends of earnings by subsidiaries to a company holding all their stock and controlling them in conducting a single enterprise, the result of the transfers being merely that the main company became the holder of debts in the business, previously due from one subsidiary to another, were not taxable as income under the Income Tax Act of 1913, where the earnings were accumulated before the taxing year and had practically become capital.