TRICOU

v.

HELVERING, COMMISSIONER OF INTERNAL REVENUE

Citator

Cited By

• Kulukundis Shipping Co. v. Amtorg Trading Corp., 126 F.2d 978 (2d Cir. 1942)
  …uch clauses than formerly was done, since it is not necessary to do so in order to decide the case before us.” See In re Utility Oil Corporation, 2 Cir., 1934, 69 F. 2d 524, 525, 526, certiorari denied Petroleum Nav. Co. v. Utility Oil Corporation, 292 U.S. 655, 54 S.Ct. 866, 78 L.Ed. 3504, where we intimated that The Atlanten should perhaps be reconsidered in the light of the subsequent enactment of the Arbitration Act.…
• Farr & Co. v. CIA. Intercontinental de Navegacion de Cuba, 243 F.2d 342 (2d Cir. 1957)
• Richards v. Commissioner of Internal Revenue, 81 F.2d 369 (9th Cir. 1936)
  …Board was whether or not the real property was “held by the taxpayer primarily for sale in the course of his trade or business.” The determination of this issue is the ultimate fact. See Tricou v. Helvering (C.C.A.9) 68 F.(2d) 280, certiorari denied 292 U.S. 655, 54 S.Ct. 865, 78 L.Ed. 1503, and rehearing denied 293 U.S. 629, 55 S.Ct. 67, 79 L.Ed. 715, and Winnett v. Helvering (C.C.A.9) 68 F.(2d) 614. The Board determined the ultimate fact to be: „ , . . , , , .. , . . That the lots were íeld by the petit…