Helvering v. Rebsamen Motors, Inc.
Court of Appeals for the Eighth Circuit
1Opinion of the Court
SANBORN, Circuit Judge.
The question in this case is whether the words “gains from the sale of stock” as used in § 351(b) (1) (A) of the Revenue Act of 1934 defining a “personal holding company,” c. 277, 48 Stat. 680, 751, 26 U.S. C.A. Int.Rev.Acts, pages 757, 758, include gains derived by a corporation from the final liquidation of a subsidiary corporation.
Congress in the Revenue Act of 1934, § 351(a), imposed a heavy surtax on the adjusted net income of every personal holding company. It was provided, § 351 (b) (1), that a corporation was a “personal holding company” if - “(A) at least 80…
2Cases cited14 opinions
- Crooks v. HarrelsonSupreme Court of the United States · 1930
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- White v. United StatesSupreme Court of the United States · 1938
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3Cited by32 opinions
- Lazier v. United StatesCourt of Appeals for the Eighth Circuit · 1948
- Commissioner of Internal Revenue v. Robert M. And Sally L. Bilder. Robert M. And Sally L. Bilder v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1961
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- Musselman Hub-Brake Co. v. Com'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Western Auto Supply Company and Beneficial Finance Co. v. Gamble-Skogmo, Inc.Court of Appeals for the Eighth Circuit · 1965
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