JEWELL RIDGE COAL CORP.
v.
LOCAL NO. 6167, UNITED MINE WORKERS OF AMERICA, ET AL.

U.S. | 1945-01-02
No. 721
323 U.S. 707 Supreme Court of the United States (1945) Positive Treatment
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  • …the determination of the Commissioner that the cash was taxable as a dividend, 1 T. C. 478, but was reversed by the Circuit Court of Appeals. 144 F. 2d 272. On a showing of importance to the administration of the Revenue Acts, we granted certiorari. 323 U. S. 707. The precise question is whether the distribution of cash in this recapitalization “has the effect of the distribution of a taxable dividend” under § 112 (c) (2) of the Revenue Act of 1936 and as such is fully taxable, or is taxable only at the rat…

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