COMMISSIONER OF INTERNAL REVENUE
v.
TRUSTEES COMMON STOCK JOHN WANAMAKER PHILADELPHIA ET AL.
COMMISSIONER OF INTERNAL REVENUE
TRUSTEES COMMON STOCK JOHN WANAMAKER PHILADELPHIA ET AL.
178 F.2d 10
United States Court of Appeals for the Third Circuit (1949)
Negative Treatment
Cited by 10 cases
Opinion of the Court
PER CURIAM
The sole question in this case is whether cash receipts by the taxpayers resulting from the sale by them of stock in a corporation to its wholly owned subsidiary are taxable as dividends under Section 115(g) of the Internal Revenue Code, 26 U.S.C.A. § 115(g). Upon the authority of Mead Corporation v. Commissioner of Internal Revenue, 3 Cir. 1940, 116 F. 2d 187, and for the reasons well stated in the opinion filed by Judge Opper for the Tax Court in banc, 11 T.C. 365, we hold that they are not so taxable.
The decision of the Tax Court will be affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Commissioner OF Internal Revenue v. Pope, 239 F.2d 881 (1st Cir. 1957)
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Blaschka v. The United States, 393 F.2d 983 (Ct. Cl. 1968)
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Broadview Lumber Co., Inc. v. United States, 561 F.2d 698 (7th Cir. 1977)
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Mead Corp. v. Commissioner of Internal Revenue, 116 F.2d 187 (3d Cir. 1940)