Bass v. Commissioner of Internal Revenue‪.‬

Edith B. Bass, petitioner herein, brings for review a decision of the Board of Tax Appeals upholding the Commissioners determination that there is a deficiency of $150,596.51 in petitioners income tax for the calendar year 1937. Practically the entire amount of the deficiency resulted from a ruling that an issue of preferred stock by Bird & Son, Inc. to its shareholders incident to a readjustment of the corporations capital structure constituted a taxable stock dividend under the Revenue Act of 1936, 49 Stat. 1648. Relevant provisions of the Act are copied in the footnote.