Legal Opinion
The Factories Investment Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided March 10, 1964No. 128, Docket 28369PublishedCited by 19 opinions
1Opinion of the Court
J. JOSEPH SMITH, Circuit Judge.
The Commissioner determined deficiencies in petitioner Factories Investment Corporation’s income tax returns for the fiscal years ending June 30, 1958 and 1959 in the respective amounts of $6,432.05 and $6,474.52, on accumulated earnings of a corporation availed of for the purpose of avoiding tax in respect of its shareholders. The Tax Court sustained the Commissioner, and the taxpayer corporation has appealed. We find no error and affirm the judgment.
There is no real dispute as to the underlying facts, which are set out in considerable detail in the opinion of…
2Cases cited5 opinions
- R. Gsell & Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Latchis Theatres of Keene, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1954
- Georgia Rail Road & Banking Co. v. MusgroveSupreme Court of the United States · 1949
- Raymond I. Smith, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
- Trico Products Corporation v. McGowanCourt of Appeals for the Second Circuit · 1948
3Cited by19 opinions
- John P. Scripps Newspapers v. CommissionerUnited States Tax Court · 1965
- Bremerton Sun Publishing Co. v. CommissionerUnited States Tax Court · 1965
- Sears Oil Co., Inc., on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1966
- Electric Regulator Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
- Atlantic Properties, Inc. v. CommissionerUnited States Tax Court · 1974
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