Legal Opinion

Young Motor Company, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the First Circuit

Decided December 28, 1964No. 6339_1PublishedCited by 12 opinions

1Opinion of the Court

HARTIGAN, Circuit Judge.

This is a petition by a corporate taxpayer to review a decision of the Tax Court of the United States deciding that there are deficiencies in its income tax for the calendar years 1950, 1951, and 1952 under Sec. 102(a) of the Internal Revenue Code of 1939 which imposes a surtax on corporations improperly accumulating surplus. This is the third appeal to this court from a decision of the Tax Court in this case. Young Motor Company v. C. I. R., 281 F.2d 488 (1st Cir. 1960), reversing 32 T.C. 1336 (1959) and C. I. R. v. Young Motor Company, 316 F.2d 267 (1st Cir. 1963),…

2Cases cited5 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  3. Barrow Manufacturing Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
  4. Young Motor Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1960
  5. Commissioner of Internal Revenue v. Young Motor Company, Inc.Court of Appeals for the First Circuit · 1963

3Cited by12 opinions

  1. Thomas Worcester v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1966
  2. Fall River Gas Appliance Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1965
  3. Mead's Bakery, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
  4. The Cheyenne Newspapers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1974
  5. Apollo Industries, Inc., Etc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1966

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