United States Board of Tax Appeals June 12, 1931, Docket Nos. 34131, 38095. (Canfield v. Commissioner)

lead-opinion

*700OPINION.

Seawell:

The applicable law in the instant case is found in the Revenue Act of 1921 and reads as follows:

Sec. 201. (a) That the term “dividend” when used in this title * * * means any distribution made by a corporation to its shareholders or members, whether in cash or in other property, out of its earnings or profits accumulated since February 28, 1913, * * *

*701(b)