Legal Opinion
Commissioner of Internal Revenue v. State-Adams Corporation
Court of Appeals for the Second Circuit
Decided October 31, 1960No. 37, Docket 26100PublishedCited by 26 opinions
1Opinion of the Court
CLARK, Circuit Judge.
Petitioner asserted deficiencies amounting to $88,558.18 in the income and excess profit taxes due from respondent corporation for the year 1951. The Tax Court held that respondent was not a corporation for tax purposes and therefore owed no tax. 32 T.C. 365. This petition for review followed.
In its corporate income tax return for 1951, respondent, following its practice since its incorporation in 1933, reported no net income. After reporting the receipt of rent in the sum of $140,000 respondent deducted $984.32 as “legal services and collection charges,” and deducted the…
2Cases cited8 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Investors Corporation v. HoeyCourt of Appeals for the Second Circuit · 1944
- Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Howard A. Jackson and Elizabeth D. Jackson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
3 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Strong v. CommissionerUnited States Tax Court · 1976
- Bolger v. CommissionerUnited States Tax Court · 1973
- T. M. Britt and Jane Britt v. The United States of AmericaCourt of Appeals for the Fifth Circuit · 1970
- United Food and Commercial Workers Union v. Progressive SupermarketsDistrict Court, D. New Jersey · 1986
- Marvin Sherwin v. United StatesCourt of Appeals for the Ninth Circuit · 1963
21 more not listed; retrieve them via the Exa API.