Legal Opinion
American Coast Line v. Commissioner of Int. Rev.
Court of Appeals for the Second Circuit
Decided February 3, 1947No. 80, Docket 20301PublishedCited by 14 opinions
1Opinion of the Court
L. HAND, Circuit Judge.
This is an appeal from an order of the Tax Court which assessed a deficiency in excess profits tax against the petitioner for the year 1940, and dismissed its petition for lack of jurisdiction, so far as it sought relief under § 722. Two questions arise: (1) Whether any excess profits tax was due for the year 1940; and (2), if so, whether the Tax Court had jurisdiction to entertain an application for relief under § 722(d) of the Internal Revenue Act. The facts are as follows. The petitioner is a corporation organized in 1933, all of whose 100 shares were held in 1939 by…
2Cases cited3 opinions
- Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
- Kirschenbaum v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
- Brooklyn Nat. Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
3Cited by14 opinions
- Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
- United States v. Koppers Co.Supreme Court of the United States · 1955
- Fidler v. CommissionerUnited States Tax Court · 1953
- Messer v. CommissionerUnited States Tax Court · 1953
- Pohatcong Hosiery Mills, Inc. v. CommissionerCourt of Appeals for the Third Circuit · 1947
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