Legal Opinion

Commissioner v. Combs

Court of Appeals for the Ninth Circuit

Decided April 11, 1935No. 7523Published

1Opinion of the Court

WILBUR, Circuit Judge.

The Commissioner of Internal Revenue determined a deficiency in the tax of the respondents for the years 1925 and 1926 amounting to $7,369.22. This deficiency it appears was assessed upon the theory that' the respondents were acting as' an association and therefore taxable under the Revenue Act of 1926, § 2 (a), 44 Stat. 9 (26' USCA § 1262 (a), as interpreted by Treasury Regulations 69, promulgated'under that act, Arts. 1502, 1504. The-'Board of Tax Appeals reversed the decision of the Commissioner upon the ground that the respondents were not an association, and the…

2Cases cited10 opinions

  1. Hecht v. MalleySupreme Court of the United States · 1924
  2. Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
  3. Hecht v. MalleySupreme Court of the United States · 1924
  4. Helvering v. Twin Bell Oil SyndicateSupreme Court of the United States · 1934
  5. Commissioner of Internal Revenue v. BrouillardCourt of Appeals for the Tenth Circuit · 1934

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