CHIANESE

v.

UNITED STATES

Citator

Cited By

• Ivan Allen Co. v. United States, 422 U.S. 617 (U.S. 1975)
  …isposal. The question, therefore, is not how much capital of all sorts, but how much in the way of quick or liquid assets, it is reasonable to keep on hand for the business. United Block Co. v. Helvering, 123 F. 2d 704, 705 (CA2 1941), cert. denied, 315 U. S. 812 (1942); Smoot Sand & Gravel Corp. v. Commissioner, 274 F. 2d 495, 501 (CA4), cert. denied, 362 U. S. 976 (1960) (liquid assets provide “a strong indication” of the purpose of the accumulation); Electric Regulator [*629] Corp. v. Commissioner, 336 F.…
• Whitney Chain & MFG. Co. v. Commissioner of Internal Revenue, 149 F.2d 936 (2d Cir. 1945)
  …dy market in 1939. Any one of these three methods would have distributed the earnings without reducing the quick assets available for use in the corporation’s business. See United Block Co. v. Helvering, 2 Cir., 123 F. 2d 704, 705, certiorari denied 315 U.S. 812, 62 S.Ct. 797, 86 L.Ed. 1211. And the Tax Court thought these methods “might be expected to have occurred to a directorate of the calibre of the petitioner’s” and that “the existence of such obvious alternatives” contradicts the taxpayer’s claim th…
• Affiliated Enters., Inc. v. Commissioner of Internal Revenue, 140 F.2d 647 (10th Cir. 1944)
  …ted here. The petitioner was before this court in Commissioner of Internal Revenue v. Affiliated Enterprises, Inc., 10 Cir., 123 F. 2d 665, involving the income from the contract issued by it in the years 1934, 1935 and 1936. Certiorari was denied, 315 U.S. 812, 62 S.Ct. 796, 86 L.Ed. 1211. This court is bound by that decision, so far as it is applicable here. The same contract issued by the petitioner in those years was used for the year 1937, and the question presented here is set forth in petitioner’s b…

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