Legal Opinion
Long v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided May 20, 1946No. 10111PublishedCited by 12 opinions
1Opinion of the Court
MILLER, Circuit Judge.
The petitioner, A. J. Long, Jr., seeks a review, pursuant to the provisions of §§ 1141, 1142 of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, §§ 1141, 1142, of the decision of the Tax Court of the United States holding that there was a deficiency in his income tax for the calendar year 1939 in the amount of $43,057.05. The question involved is whether a distribution of $9 per share which was paid by The A. Nash Company on its common stock in December 1939 was a dividend payment out of earnings and so taxable, or in part a nontaxable return of capital.
The A. Nash…
2Cases cited13 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
- Kirschenbaum v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
- Commissioner of Internal Revenue v. QuackenbosCourt of Appeals for the Second Circuit · 1935
8 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Avco Mfg. Corp. v. CommissionerUnited States Tax Court · 1956
- United States v. Lesoine United States v. MarcusCourt of Appeals for the Ninth Circuit · 1953
- Owensboro Wagon Co. v. CommissionerUnited States Tax Court · 1952
- Estate of Chandler v. CommissionerUnited States Tax Court · 1954
7 more not listed; retrieve them via the Exa API.