WINGET KICKERNICK CO. ET AL.
v.
SIL-O-ETTE UNDERWEAR CORP.

U.S. | 1937-10-11
No. 314
302 U.S. 723 Supreme Court of the United States (1937) Positive Treatment
Cited by 4 cases

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  • Sherwood Bros., Inc. v. Dist. of Columbia, 113 F.2d 162 (D.C. Cir. 1940)
    …take the contrary view with respect to calculating the time for taking an appeal in federal judicial proceedings and for performing the acts necessary to an appeal,9 including Walker v. Hazen, 1937, 67 App.D.C. 188, 90 F. 2d 502, certiorari denied, 302 U.S. 723, 58 S.Ct. 44, 82 L.Ed. 559. The reasons given to support this view are varied and highly technical, some of them resting upon doubtful assumptions and contradictory premises.10 We do not consider it [*165] necessary to discuss them fully. It is suf…
  • …easonable cause and not due to willful neglect.” Absent such a showing by the taxpayer, imposition of the addition is mandatory. Cf. Fidelity & Columbia Trust Co. v. Commissioner [*1150] of Internal Revenue, 90 F. 2d 219, 223 (6th Cir.), cert. den., 302 U.S. 723, 58 S.Ct. 44, 82 L.Ed. 558 (1937). Although we are sympathetic with the plight of the executrix and would have preferred that the IRS have settled this matter at the administrative level and thereby avoided a harsh result, we cannot reverse the deci…
  • Uhl Est. Co. v. Commissioner of Internal Revenue, 116 F.2d 403 (9th Cir. 1940)
    …18 certiorari denied 302 U.S. 713, 58 S.Ct. 32, 82 L.Ed. 551; Noteman v. Welch, 1 Cir., 108 F. 2d 206, 215; Sabatini v. Commissioner, 2 Cir., 98 F. 2d 753, 756; Fidelity & Columbia T. Co. v. Commissioner, 6 Cir., 90 F. 2d 219, 223, certiorari denied 302 U.S. 723, 58 S.Ct. 44, 82 L.Ed. 558; National Contracting Co. v. Commissioner, 8 Cir., 105 F. 2d 488, 492; American Milk Products Corp. v. United States, Ct.Cl., 41 F. 2d 966, 969. R.S. 5392, 18 U.S.C.A. § 231; United States v. John Bailey, 9 Pet. 238, 255,…

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