Legal Opinion

Bazley v. Commissioner

Supreme Court of the United States

Decided June 16, 1947No. 287PublishedCited by 177 opinions

1Opinion of the CourtJustice Frankfurter

The proper construction of provisions of the Internal Revenue Code relating to corporate reorganizations is involved in. both these cases. Their importance to the Treasury as well as to corporate enterprise led us to grant certiorari, 329 U. S. 695, 329 U. S. 701. While there are differences in detail to which we shall refer, the two cases may be disposed of in one opinion.

In the Bazley case, No. 287, the Commissioner of Internal Revenue assessed an income tax deficiency against the taxpayer for the year 1939. Its validity depends on the legal significance of the recapitalization in that year…

2Cases cited10 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Dobson v. CommissionerSupreme Court of the United States · 1944
  3. Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
  4. LeTulle v. ScofieldSupreme Court of the United States · 1940
  5. Commissioner v. Estate of BedfordSupreme Court of the United States · 1945

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3Cited by177 opinions

  1. Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
  2. Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
  3. Fed. Sec. L. Rep. P 95,494 Great Western Bank & Trust v. Sol KotzCourt of Appeals for the Ninth Circuit · 1976
  4. Goodstein v. CommissionerUnited States Tax Court · 1958
  5. J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966

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