UNDERWOOD ET AL.

v.

ILLINOIS CENTRAL RAILROAD CO.

Citator

Cited By

• Associated Tel. & Tel. Co. v. United States, 306 F.2d 824 (2d Cir. 1962)
  …nds” paid by personal holding companies. Brooklyn Nat’l Corp., 5 T.C. 892 (1945), aff’d, 157 F. 2d 450 (2 Cir.), cert. denied, 329 U.S. 733, 67 S.Ct. 96, 91 L.Ed. 634 (1946); St. Louis Co. v. United States, 237 F. 2d 151 (3 Cir. 1956), cert. denied, 352 U.S. 1001, 77 S.Ct. 558, 1 L.Ed.2d 546 (1957). Furthermore, the differences in purpose are obvious between the “deemed to have been paid” foreign tax credit provision and the “dividends paid” provision for computing personal holding company undistributed inc…
• BOX v. S. Ga. Ry. Co., 433 F.2d 89 (5th Cir. 1970)
  …340 U.S. 573, 71 S.Ct. 428, 95 L.Ed. 547. The deposition testimony was a guess, demonstrated by the later test to be without value. See Illinois Central R. R. Co. v. Underwood, 5 Cir. 1956, 235 F. 2d 868, specifically Note 26 at page 878, cert. den. 352 U.S. 1001, 77 S.Ct. 557, 1 L.Ed.2d 546. . Roberts was also impeached by his pretrial deposition. Again, the deposition testimony was a rough guess while the trial testimony was based on a re-examination of the scene. See footnote [2], supra. . These princip…
• Baker v. United States, 460 F.2d 827 (8th Cir. 1972)
  …was limited to the amount by which current earnings exceeded the existing deficit. These excess earnings were the only earnings which qualified as “accumulated.” See e. g., St. Louis Co. v. United States, 237 F. 2d 151 (3d Cir. 1956), cert. denied, 352 U.S. 1001, 77 S.Ct. 558, 1 L.Ed.2d 546 (1957). See also, Van Norman Co. v. Welch, 141 F. 2d 99 (1st Cir. 1944); Shellabarger Grain Products Co. v. Commissioner of Internal Revenue, 146 F. 2d 177 (7th Cir. 1944). Taxpayers rely upon this history to support…