Legal Opinion

Lloyd v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided March 4, 1946No. 8976PublishedCited by 12 opinions

1Opinion of the Court

O’CONNELL, Circuit Judge.

This petition for review of the Tax Court’s decision presents a rather narrow question for our consideration. We are required to pass on the correctness of the Commissioner’s holding that proceeds from the sale of certain unmatured coupons clipped from tax-exempt municipal bonds’ (later sold) were includible in taxable income of the seller. The taxpayer contends that the proceeds in question were tax-exempt as being interest upon the obligation of a political subdivision of a State within the meaning of Section 22(b) (4) of the Internal Revenue Code.

Taxpayer is a…

2Cases cited17 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Helvering v. HorstSupreme Court of the United States · 1940
  3. Dobson v. CommissionerSupreme Court of the United States · 1944
  4. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  5. John Kelley Co. v. CommissionerSupreme Court of the United States · 1946

12 more not listed; retrieve them via the Exa API.

3Cited by12 opinions

  1. Commissioner of Internal Revenue v. Philadelphia Transp. Co.Court of Appeals for the Third Circuit · 1949
  2. Simon Jaglom and Marie Jaglom v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
  3. Bazley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1946
  4. Newlin Machinery Corp. v. CommissionerUnited States Tax Court · 1957
  5. Commissioner of Internal Revenue v. Carman. Carman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951

7 more not listed; retrieve them via the Exa API.

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