Legal Opinion
H. S. D. Co. v. Kavanagh, Collector of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided June 19, 1951No. 11251_1PublishedCited by 55 opinions
1Opinion of the Court
McAllister, circuit judge.
Appellant filed a complaint in the district court, asking for a refund of excess profits tax. It claimed that the amount in question was properly deductible from gross income in computing net income to determine income tax liability, on the ground that it was a contribution to two employees’ trusts, which were exempt from taxation. The contributions to the trusts were made during the fiscal year ending April 30, 1944; and it was claimed that they were deductible from appellant’s gross income for that year under Section 23 (p) of the Internal Revenue Code, and Section…
2Cases cited12 opinions
- Vestal v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1945
- Woodworth v. KalesCourt of Appeals for the Sixth Circuit · 1928
- Austin Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1929
- Surface Combustion Corp. v. CommissionerUnited States Tax Court · 1947
- Routzahn v. BrownCourt of Appeals for the Sixth Circuit · 1938
7 more not listed; retrieve them via the Exa API.
3Cited by55 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Estate of Emerson v. CommissionerUnited States Tax Court · 1977
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
- The Lesavoy Foundation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
- Fruehauf Trailer Co. v. CommissionerUnited States Tax Court · 1964
50 more not listed; retrieve them via the Exa API.