NATIONAL MANUFACTURE & STORES CORP.

v.

ALLEN, COLLECTOR OF INTERNAL REVENUE

Citator

Cited By (13 total)

• Catlin v. United States, 324 U.S. 229 (U.S. 1945)
  …too late to validate” the “judgment.” Dade County v. United States, 142 F. 2d 230 (C. C. A. 5), accords with the decision in this case. Contrary decisions were rendered in City of Oakland v. United States, 124 F. 2d 959 (C. C. A. 9), cert. denied, 316 U. S. 679; United States v. 243.22 Acres of Land, 129 F. 2d 678 (C. C. A. 2), cert. denied, 317 U. S. 698; Puerto Rico R. Co. v. United States, 131 F. 2d 491 (C. C. A. 2). Under the comparable provision of the 1929 act applicable in the District of Columbia,…
• Commissioner of Internal Revenue v. Air Reduction Co., Inc., 130 F.2d 145 (2d Cir. 1942)
  …arket and then sold it to employees pursuant to an employees’ stock purchase plan. Also the courts have adopted the more general interpretation of the regulation. Allen v. National Manufacture & Stores Corp., 5 Cir., 125 F. 2d 239, certiorari denied 316 U.S. 679, 62 S.Ct. 1106, 86 L.Ed. -. There the purchase of the company’s own stock on margin was made with the intention of retiring it, which was never done, however. Later the resale was made to a syndicate in order to satisfy the margin requirements. This…
• Helvering v. Edison Bros. Stores, Inc., 133 F.2d 575 (8th Cir. 1943)
  …administrative exigencies or conform to judicial decision.” Two recent decisions of circuit courts of appeals expressly deny the contention of the taxpayer here. Allen v. National Manufacture & Stores Corp., 5 Cir., 125 F. 2d 239, certiorari denied 316 U.S. 679, 62 S.Ct. 1106, 86 L.Ed. 1753; Commissioner v. Air Reduction Company, 2 Cir., 130 F. 2d 145, certiorari denied 63 S.Ct. 201, 87 L.Ed. -. In the first case mentioned, the purchase of the taxpayer’s own stock was made with the intention of retiring it…