SILCO, INC. v. UNITED STATES

No. 84-1732.

779 F.2d 282 (1986)

SILCO, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied March 3, 1986.


Attorney(s) appearing for the Case

Jenkins & Gilchrist, Patrick E. Mitchell, William P. Bowers, Dallas, Tex., for plaintiff-appellant.

Glenn L. Archer, Jr., Asst. Atty. Gen., David English Carmack, Michael L. Paup, Chief, John A. Dudeck, Jr., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant-appellee.

Before CLARK, Chief Judge, and BROWN, and GEE, Circuit Judges.


PER CURIAM.

Appellant Silco, Inc., appeals a district court decision denying its recovery of corporate federal income taxes and interest. The Internal Revenue Service (IRS) assessed these taxes against Silco when it determined that Silco improperly reported dividends on stock purchased after the corporate record date as income. The issue turns on whether the term "entitled" in the applicable Treasury Regulation is defined by (1) the stock exchange rules which follow...

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