Legal Opinion

Commissioner v. Kaufmann

Court of Appeals for the Third Circuit

Decided July 30, 1943No. 8198PublishedCited by 2 opinions

1Opinion of the Court

GOODRICH, Circuit Judge.

E. M. Rosenthal Jewelry Co., a corporation of the District of Columbia, owned in 1933 a majority of the shares of numerous corporations operating retail jewelry stores. For business reasons it was deemed expedient for Rosenthal to divest itself of the ownership of those shares. In 1933 a plan was devised which it was thought would accomplish this without the incurring of any income tax liability.

In 1933 the shareholders of Rosenthal organized a Delaware corporation, General Associates, Incorporated. Rosenthal by a writing dated August 3, 1933, stated that it thereby…

2Cases cited6 opinions

  1. Avery v. CommissionerSupreme Court of the United States · 1934
  2. Pacific National Bank v. EatonSupreme Court of the United States · 1891
  3. Tar Products Corporation v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1942
  4. Helvering v. KaufmannCourt of Appeals for the Fourth Circuit · 1943
  5. Commissioner v. LeviCourt of Appeals for the Seventh Circuit · 1943

1 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Byrne v. CommissionerUnited States Tax Court · 1970
  2. Byrne v. CommissionerUnited States Tax Court · 1970

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