456. Dividends specifically applicable; payments to meet tax.

A dividend declared by a company in pursuance of an agreement that it is to be applied by the shareholders in a certain way, for example in the purchase of issued shares of the company or in taking up debentures of the company, is nonetheless income in the shareholders' hands1. Where, however, as part of the consideration for the sale of shares, the purchaser undertakes to discharge a liability of the vendor affecting the income receivable by the vendor from such shares (for example the vendor's tax at the higher rate), the amount so paid to the vendor is