FIRST NATIONAL BANK
v.
BURNET, COMMISSIONER OF INTERNAL REVENUE

U.S. | 1931-04-27
No. 827
283 U.S. 846 Supreme Court of the United States (1931) Positive Treatment
Cited by 1 case
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  • Zuckman v. The United States, 524 F.2d 729 (Ct. Cl. 1975)
    …. Plaintiff points out that the term “substantially all,” as used elsewhere in the Internal Revenue Code, has been defined to mean “all except a negligible minority interest.” Burnet v. Bank of Italy, 46 F. 2d 629, 630 (9th Cir. 1931), cert. denied, 283 U.S. 846, 51 S.Ct. 493, 75 L.Ed. 1455 (1931). In addition, the Internal Revenue Service has for certain ruling purposes used a 90% figure as the benchmark for determining what constitutes “substantially all.” Rev.Proc. 66-34, 1966-2 Cum.Bull. 1232, 1233. The…

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