United States Board of Tax Appeals May 26, 1925, Docket No. 2055 (Appeal of Stearns)

*1253OPINION.

James :

The taxpayer bases his entire claim for a valuation of $300 on the average dividends declared and paid from 1913 to 1923. The corporation, however, has declared over that period only approximately 63 per cent of its net profits in dividends, and the balance sheet as of the close of 1921 shows an actual net worth in capital stock, surplus, and surplus reserves of $871,962.