COMMISSIONER OF INTERNAL REVENUE v. FOX

No. 11346.

218 F.2d 347 (1954)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Maurice FOX, Respondent.

United States Court of Appeals Third Circuit.

Decided December 30, 1954.


Attorney(s) appearing for the Case

Davis W. Morton, Jr., Washington, D. C. (H. Brian Holland, Asst. Atty. Gen., Hilbert P. Zarky, Ellis N. Slack, Sp. Assts. to Atty. Gen., Washington, D.C., on the brief), for petitioner.

Morris M. Schnitzer, Newark, N. J., for respondent.

Before BIGGS, Chief Judge, and MARIS and HARLAN, Circuit Judges.


BIGGS, Chief Judge.

The taxpayer, on a cash basis, owned investment shares in one hundred federal savings and loan associations scattered throughout the United States. The controversy concerns the proper year for the taxation of dividends of twenty-seven of these associations, all located outside New Jersey where the taxpayer had his residence. The associations declared year-end dividends payable on or before December 31, 1949. The taxpayer could have collected his...

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