Legal Opinion
Carragan v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided May 12, 1952No. 22238_1PublishedCited by 65 opinions
1Opinion of the Court
FRANK, Circuit Judge,
1. Petitioner was employed by the Japanese-owned Takamine corporation and its immediate predecessor from 1916 until its liquidation in 1942. On May 20, 1942, when the liquidation had been largely completed, its board of directors adopted the following resolution:
“Whereas, the liquidation of Taka-mine Corporation has been substantially completed; and
“Whereas, in accordance with precedent, the directors deem it fitting and proper to recognize the length of time its officers and employees have served the Corporation and the value of their services by granting to each,…
2Cases cited4 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Willkie v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Nickelsburg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
3Cited by65 opinions
- Commissioner of Internal Revenue v. James E. Peurifoy, Paul v. Stines and Betty O. Stines, John S. Hall and Doris D. HallCourt of Appeals for the Fourth Circuit · 1958
- Leo C. Cockrell, and Carol P. Cockrell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- William W. Steinhort and Mildred Steinhort v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
- Calvin E. Wright, District Director of Internal Revenue v. Richard v. Hartsell, Marjorie HartsellCourt of Appeals for the Ninth Circuit · 1962
- Harvey v. CommissionerUnited States Tax Court · 1959
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