Legal Opinion
American Range Lines, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 3, 1952No. 22369_1PublishedCited by 25 opinions
1Opinion of the Court
FRANK, Circuit Judge.
When taxpayer’s sole stockholder, Mrs. Rogers, litigated the question of her taxes arising from this very transaction, the Third Circuit (reversing the Tax Court) held that the entire consideration paid by Liberty (i. e., American Liberty Steamship Corporation) was paid to Mrs. Rogers for her consent — -evidenced by the November 27, 1944 contract — to terminate the so-called “joint venture” which had been operating under the August 1943 contract. See Rogers v. Commissioner of Internal Revenue, 3 Cir., 180 F.2d 720. We respectfully disagree with that conclusion. For we…
2Cases cited16 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Ford Motor Co. v. National Labor Relations BoardSupreme Court of the United States · 1939
- United States v. Joliet & Chicago RailroadSupreme Court of the United States · 1942
- Commissioner of Int. Rev. v. Transport Trad. & Term. Corp.Court of Appeals for the Second Circuit · 1949
- Underwood v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1932
11 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Marvin Dudley v. Gilbert P. SmithCourt of Appeals for the Fifth Circuit · 1975
- C.B.C. Super Markets, Inc. v. CommissionerUnited States Tax Court · 1970
- Gillig v. Nike, Inc.Court of Appeals for the Federal Circuit · 2010
- Gammill v. CommissionerUnited States Tax Court · 1974
- Texas Capital Securities Management, Inc. v. Sandefer, Texas Court of Appeals, 6th District (Texarkana)2002
20 more not listed; retrieve them via the Exa API.