Filed November 25, 2014
Speculative diminution in a company’s ability to pay future, undeclared “dividends” is, in reality, just an injury to the company’s profits. Sprouse v. Comm’r of Internal Revenue, 122 F.2d 973, 976 (9th Cir. 1941) aff’d sub nom. Helvering v. Sprouse, 318 U.S. 604 (1943); 11 Fletcher Cyc. Corp. § 5321 (Supp. 2014) (“[P]rofits belong to the corporation and not its shareholders until the declaration of a dividend.”)