RICHARDSON
v.
COMMISSIONER OF INTERNAL REVENUE

U.S. | 1946-01-28
No. 682
Mr. Justice Rutledge took no part in the consideration or decision of this application.
326 U.S. 796 Supreme Court of the United States (1946) Positive Treatment
Cited by 8 cases

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  • Hamm v. Commissioner OF Internal Revenue, 325 F.2d 934 (8th Cir. 1963)
    …stock was the stated figure and .not ungently hints that the taxpayers might well consider themselves fortunate that it was not higher. An identical finding was upheld in Richardson v. Commissioner, 151 F. 2d 102, 104-105 (2 Cir. 1945), cert, denied 326 U.S. 796, 66 S.Ct. 490, 90 L.Ed. 485, although one judge expressed doubt about the actual evaluation standard employed in that case. Somewhat similar language was involved and also upheld in Gross v. Commissioner, 92 F. 2d 621, 622 (7 Cir. 1937), although th…
  • …cks of securities, the principle of “blockage” has long been recognized. Rushton v. Commissioner, 498 F. 2d 88 (5 Cir. 1974); Warner v. Commissioner, 193 F. 2d 328 (2 Cir. 1952); Richardson v. Commissioner, 151 F. 2d 102 (2 Cir. 1945), cert. denied, 326 U.S. 796 (1946); Bull v. Smith, 119 F. 2d 490 (2 Cir. 1941). This principle in essence is that the fair market value of a large block of stock actually may be substantially less than the quoted market price because of the inability of the market to absorb a…
  • …fair market value. United States v. Cartwright, 411 U.S. 546, 551, 93 S.Ct. 1713, 36 L.Ed.2d 528 (1973); Hazeltine Corp. v. Commissioner, 89 F. 2d 513, 519 (3d Cir. 1937); Richardson v. Commissioner, 151 F. 2d 102, 103 (2d Cir. 1945), cert. denied, 326 U.S. 796, 66 S.Ct. 490, 90 L.Ed. 485 (1946); Andrews v. Commissioner, 135 F. 2d 314, 318 (2d Cir.), cert. denied, 320 U.S. 748, 64 S.Ct. 51, 88 L.Ed. 444 (1943); Rogers v. Helvering, 107 F. 2d 394, 396 (2d Cir. 1939); W. T. Grant Co. v. Duggan, 94 F. 2d 859…
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