Legal Opinion
Hatfried, Inc. v. Commissioner of Internal Rev.
Court of Appeals for the Third Circuit
Decided June 11, 1947No. 9180PublishedCited by 113 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
This appeal is taken from the decision of the Tax Court.
Two questions are presented: (1) whether the taxpayer should be classified as a personal holding company within the meaning of Sections 501 and 502(f) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev. Code, §§ 501, 502(f); (2) whether, if the taxpayer is taxable as a personal holding company, there was a proper imposition of the penalty imposed by Section 291 of the Internal Revenue Code, 26 U.S.C.A. Int. Rcv.Code, § 291, for failure to file a personal holding company return.
The Tax Court upheld the…
2Cases cited15 opinions
- Caminetti v. United StatesSupreme Court of the United States · 1917
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Spies v. United StatesSupreme Court of the United States · 1943
- Crane v. CommissionerSupreme Court of the United States · 1947
- United States v. MurdockSupreme Court of the United States · 1934
10 more not listed; retrieve them via the Exa API.
3Cited by113 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Davis Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
108 more not listed; retrieve them via the Exa API.