DYER

v.

COMMISSIONER OF INTERNAL REVENUE

Citator

Cited By

• Cottage Sav. Ass'n v. Commissioner of Internal Revenue, 499 U.S. 554 (U.S. 1991)
  …ld remember, substance rather than form determines tax consequences. Commissioner v. Court Holding Co., 324 U. S. 331, 334 (1945); Gregory v. Helvering, 293 U. S. 465, 469-470 (1935); Shoenberg v. Commissioner, 77 F. 2d 446, 449 (CA8), cert. denied, 296 U. S. 586 (1935). Thus, the resolution of the exchange issue in these cases turns on the “materially different” concept. The Court recognizes as much. Ante, at 559-560. That the mortgage participation partial interests exchanged in these cases were “differen…
• Burdan v. Commissioner of Internal Revenue, 106 F.2d 207 (3d Cir. 1939)
  ….sections of prior Revenue Acts have received- a like construction. Burnet v. Huff, 288 U.S. 156, 53 S.Ct. 330, 77 L.Ed. 670 (Revenue Act of 1918, 40 Stat. 1057); Shoenberg v. Commissioner of Internal Revenue, 9 Cir., 77 F. 2d 446 certiorari denied, 296 U.S. 586, 56 S.Ct. 101, 80 L.Ed. 414 (Revenue Act of 1928, 45 Stat. 791); Howard v. Commissioner of Internal Revenue, 6 Cir., 56 F. 2d 781, certiorari denied 287 U.S. 619, 53 S.Ct. 19, 77 L.Ed. 537 (Revenue Act of 1921, 42 Stat. 227). The “identifiable even…
• Dayton Co. v. Commissioner of Internal Revenue, 90 F.2d 767 (8th Cir. 1937)
  …ive here. The action of the Board in disallowing this deduction is affirmed. The result upon the entire case is affirmance of the order of the Board and dismissal of the petition. In Shoenberg v. Commissioner, 77 F.(2d) 446, 448, certiorari denied 296 U.S. 586, 56 S.Ct. 101, 80 L.Ed. 414, this court stated the rule as follows: “The Revenue Act here involved (Act of 1928, 45 Stat. 791, 26 U.S.C.A. § 2001 et seq. [now 26 U.S.C.A. § 1 et seq., and notes]) as well as earlier and later Revenue Acts permit ded…

  ← 1 / 2 →