Paul E. Kummer Realty Company v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• suggesting that payments to shareholders that were “almost identical” to their ownership interest indicated disguised distributions
• stating that the fact that amounts received by shareholders were “almost identical” to the percentage of stock held by each shareholder was indicative of disguised distributions
• “[T]he absence of dividends to stockholders out of available profits justifies an inference that some of the purported compensation really represented a distribution of profits as dividends.”
• “[T]he absence of dividends to stockholders out of available profits justifies an inference that some of the purported compensation really represented a distribution of profits as dividends.”
• \The Tax Court is the judge of the credibility of witnesses and is not compelled to accept the testimony of a witness even if it is not contradicted.\

Source: CourtListener parenthetical corpus (CC0).