United States Supreme Court

In the context of sections of the Internal Revenue Code that set the conditions for treating certain corporate distributions as returns of capital, nontaxable to the recipient, a distributee accused of criminal tax evasion may claim return-of-capital treatment without producing evidence that either he or the corporation intended a return of capital when the distribution occurred.

Appellate Information

• Decided 03/03/2008
• Published 03/03/2008

Judges

Court

• United States Supreme Court

Counsel