Legal Opinion

Commissioner of Int. Rev. v. Coastwise Transp. Corp.

Court of Appeals for the First Circuit

Decided May 18, 1934No. 2866PublishedCited by 20 opinions

1Opinion of the Court

BINGHAM, Circuit Judge.

The Coastwise Transportation Corporation acquired a fleet of ships from the American Hawaiian Company in 19*221 and gave, as part payment therefor, serial notes of the face value of $608,400 secured by mortgage on the ships. In 1924, the corporation purchased for $75,000 two of these notes having a face value of $152,000, thereby making a gain of $77,100; and in 19’25, by negotiations through a syndicate, acquired $456,300 of the notes in exchange for bonds having a par value of $375,000, thus making a gain of $81,-300. The mortgage notes were retired by the…

2Cases cited5 opinions

  1. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  2. Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
  3. Helvering v. American Chicle Co.Supreme Court of the United States · 1934
  4. Taylor v. VossSupreme Court of the United States · 1926
  5. Commissioner v. Coastwise Transp. Corp.Court of Appeals for the First Circuit · 1932

3Cited by20 opinions

  1. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  2. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
  3. Harold Wener v. Commissioner of Internal Revenue, Molly Wener v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
  4. Montgomery v. CommissionerUnited States Tax Court · 1975
  5. Helvering v. A. L. Killian Co.Court of Appeals for the Eighth Circuit · 1942

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