Legal Opinion
Ivan Allen Company v. United States
Court of Appeals for the Fifth Circuit
Decided May 3, 1974No. 73-2866PublishedCited by 6 opinions
1Opinion of the Court
INGRAHAM, Circuit Judge:
The issue on this appeal concerns the standard for measuring the amount of a corporation’s liquid assets in determining the applicability of the tax imposed upon a corporation for not distributing to its shareholders the earnings and profits that exceed its reasonable business needs. 1 More specifically, we must decide whether securities, which have appreciated substantially in value, should be measured by their original cost to the corporate taxpayer, or at the fair market value less the expense of conversion into cash. The district court held for taxpayer Ivan Allen…
2Cases cited8 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Henry Van Hummell, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1966
- Battelstein Investment Company v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Golconda Mining Corp. v. CommissionerUnited States Tax Court · 1972
- Golconda Mining Corp. v. CommissionerUnited States Tax Court · 1972
3 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Ivan Allen Co. v. United StatesSupreme Court of the United States · 1975
- Alma Piston Co. v. CommissionerUnited States Tax Court · 1976
- Rochow v. Life Insurance Co. of North AmericaDistrict Court, E.D. Michigan · 2012
- Suwannee Lumber Mfg. Co. v. CommissionerUnited States Tax Court · 1979
- Ivan Allen Co. v. United StatesSupreme Court of the United States · 1975
1 more not listed; retrieve them via the Exa API.