Legal Opinion

Patten Fine Papers, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided November 26, 1957No. 12059PublishedCited by 23 opinions

1Opinion of the Court

LINDLEY, Circuit Judge.

This petition for review of a decision of the United States Tax Court raises essentially three issues: first, should petitioner Patten Fine Papers, Inc., a personal holding company, be allowed to deduct its federal income tax paid in 1950 in computing its undistributed sub-chapter A net income for 1950; second, may it deduct the net capital loss of a wholly owned subsidiary for a year in which the subsidiary was liquidated; and, third, may it deduct the net capital loss of the same subsidiary for the year prior to the year of liquidation. Each of these issues was…

2Cases cited5 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  3. Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
  4. De Soto Securities Company v. Commission of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
  5. American Trans-Ocean Navigation Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956

3Cited by23 opinions

  1. Huyler's (Corp.) v. CommissionerUnited States Tax Court · 1962
  2. Commissioner of Internal Revenue v. Virginia Metal Products, Inc., Virginia Metal Products, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1961
  3. Arc Realty Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1961
  4. Arc Realty Co. v. CommissionerUnited States Tax Court · 1960
  5. Estate of Guzzardi v. Director, Division of TaxationNew Jersey Tax Court · 1995

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