Legal Opinion
Thornley v. Commissioners of Internal Revenue
Court of Appeals for the Third Circuit
Decided January 15, 1945No. 8548PublishedCited by 35 opinions
1Opinion of the Court
KALODNER, District Judge.
This is a petition to review the decision of the Tax Court. It involves a deficiency in income taxes for the year 1937. The petitioner was a member of a co-partnership trading as N. W. Ayer & Son, an advertising agency. On January 1, 1927, he held a 10% interest in the partnership. On May 1, 1929, the business and assets of the partnership were transferred to a corporation, N. W. Ayer & Son, Incorporated, pursuant to a contract between the partners and the newly-formed corporation, and thereupon the corporation’s shares of stock were issued to the partners in…
2Cases cited14 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- United States v. PhellisSupreme Court of the United States · 1921
- Southern Pacific Co. v. LoweSupreme Court of the United States · 1918
- Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
- Helvering v. RankinSupreme Court of the United States · 1935
9 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Emmette L. Barran and Martha Barran v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
- Hugh H. Earle, Former Collector of Internal Revenue v. Angela MacEvoy WoodlawCourt of Appeals for the Ninth Circuit · 1957
- Smith v. CommissionerUnited States Tax Court · 1985
- Swiren v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1950
- Hatch's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1952
30 more not listed; retrieve them via the Exa API.