Legal Opinion
Sisto Financial Corporation v. Commissioner of Int. Rev.
Court of Appeals for the Second Circuit
Decided April 27, 1945No. 214PublishedCited by 20 opinions
1Opinion of the Court
L. HAND, Circuit Judge.
This appeal is a sequel to our decision upon an appeal of the Commissioner from an order of the Tax Court, expunging an assessment for deficiency in the taxpayer’s income tax for the year 1936. Commissioner of Internal Revenue v. Sisto Financial Corporation, 139 F.2d 253. The only question then left open was the value of 159,899 shares of the stock of the Barium Stainless Steel Corporation, received by the taxpayer on August 31, 1936, in exchange for the notes of a predecessor to that corporation — the Barium Steel Corporation. Upon the present trial the taxpayer…
2Cases cited4 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
- Uncasville Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
- Commissioner of Internal Revenue v. Sisto F. Corp.Court of Appeals for the Second Circuit · 1943
3Cited by20 opinions
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- United States v. Randolph C. Fernon, Jr., Etc. And Susanna F. FernonCourt of Appeals for the Fifth Circuit · 1981
- Estate of Goodall v. CommissionerCourt of Appeals for the Eighth Circuit · 1968
- Commissioner of Internal Revenue v. Erie Forge Co.Court of Appeals for the Third Circuit · 1948
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