MUNSON STEAMSHIP LINE

v.

BERGEN LLOYD; AND BERGEN LLOYD V. MUNSON STEAMSHIP LINE

Citator

Cited By (11 total)

• Ivan Allen Co. v. United States, 422 U.S. 617 (U.S. 1975)
  …we deal here, in a sense, with a state of mind. But it has been said that the statute, without the support of the presumption, would “be practically unenforceable . . . .” United Business Corp. v. Commissioner, 62 F. 2d 754, 755 (CA2), cert. denied, 290 U. S. 635 (1933). What is required, then, is a comparison of accumulated earnings and profits with “the reasonable needs of the business.” Business needs are critical. And need, plainly, to use mathematical terminology, is a function of a corporation's liquid…

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• Given v. Commissioner OF Internal Revenue, 238 F.2d 579 (8th Cir. 1956)
  …by the parties, the Tax Court may ordinarily regard the question as having legally been waived by him and refuse to consider it. United Business Corporation of America v. Commissioner, 19 B.T.A. 809, affirmed, 2 Cir., 62 F. 2d 754, certiorari denied 290 U.S. 635, 54 S.Ct. 53, 78 L.Ed. 552; Kottemann v. Commissioner, 9 Cir., 81 F. 2d 621. See also Helvering v. Tetzlaff, 8 Cir., 141 F. 2d 8, 11-12. And whatever may be our right, if any, to allow a taxpayer to have the benefit of the statute of limitations in…
• Lustman v. Commissioner OF Internal Revenue, 322 F.2d 253 (3d Cir. 1963)
  …the fact remains that no proof was offered in support thereof and, consequently, the [*259] question cannot be considered upon review here. United Business Corp. of America v. Commissioner, 19 B.T.A. 809, aff’d 2 Cir. 1933, 62 F. 2d 754, cert. den. 290 U.S. 635, 54 S.Ct. 53, 78 L.Ed. 552. The fa^t that Income Tax Returns are prepared for a taxpayer by a certified public accountant upon whom he relies does not relieve him of the consequences of error in failure to report the tax liability correctly. Hoboke…