Legal Opinion

Travelers Ins. Co. v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided April 15, 1947No. 146, Docket 20376PublishedCited by 18 opinions

1Opinion of the Court

AUGUSTUS N. HAND, Circuit Judge.

The taxpayer, Travelers Insurance Company, prior to 1896 acquired 2,000 shares of the outstanding 50,000 shares of the capital stock of Northwestern Telegraph Company (hereinafter called “Northwestern”) which it has since held continuously. Prior to July 1, 1881, the latter operated a telegraph business and on May 7, 1881, leased to the Western Union all of its assets and property for a term of 99 years. The annual rentals after the year 1896 were $150,000 per year. By the terms of the lease, Western Union agreed to pay the rentals specified in the lease…

2Cases cited10 opinions

  1. Cromwell v. County of SacSupreme Court of the United States · 1877
  2. Southern Pacific Railroad v. United StatesSupreme Court of the United States · 1897
  3. Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
  4. New Orleans v. Citizens' BankSupreme Court of the United States · 1897
  5. The Evergreens v. NunanCourt of Appeals for the Second Circuit · 1944

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3Cited by18 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Schnitzer v. CommissionerUnited States Tax Court · 1949
  3. Fairmont Aluminum Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
  4. Miller v. National City Bank of New YorkCourt of Appeals for the Second Circuit · 1948
  5. Hubert Wesley Driggers v. Business Men's Assurance Company of AmericaCourt of Appeals for the Fifth Circuit · 1955

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