Legal Opinion
Patty v. Helvering
Court of Appeals for the Second Circuit
Decided July 18, 1938No. Ño. 12PublishedCited by 22 opinions
1Opinion of the Court
L. HAND, Circuit Judge.
This case arises on a petition to review an order of the Board of Tax Appeals, assessing the taxpayer for a deficiency in his income for the year 1928. He was a stockholder of a corporation which through two cash payments on March 6th and March 27th, 1928, decreased its outstanding capital from $2,500,000 to $1,750,000, by reducing the par value of each share from $100 to $70. He claims that this reduction fell within § 115(c) of the Revenue Act of 1928, 26 U.S.C.A. § 115 note, because the payments were “amounts distributed in partial liquidation of a corporation”, a…
2Cases cited14 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- McGuire v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1936
- Hyman v. HelveringCourt of Appeals for the D.C. Circuit · 1934
- Randolph v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1935
- Brown v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1935
9 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Flanagan v. HelveringCourt of Appeals for the D.C. Circuit · 1940
- Keefe, Collector v. CoteCourt of Appeals for the First Circuit · 1954
- Kirschenbaum v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
- Hugh H. Earle, Former Collector of Internal Revenue v. Angela MacEvoy WoodlawCourt of Appeals for the Ninth Circuit · 1957
- Anna I. Woodworth v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
17 more not listed; retrieve them via the Exa API.