First Mechanics Bank v. Commissioner of Internal Rev.
Court of Appeals for the Third Circuit
1Opinion of the Court
DAVIS, Circuit Judge.
This is an appeal from an order of the Board of Tax Appeals holding the petitioners liable for a deficiency of $20,179.53 in the income tax return of J. Philip Bird, for the year 1928.
The liability of the petitioners for the alleged deficiency depends upon the nature of the relationship between J. Philip Bird and the Canadian Car & Foundry Company, Ltd., hereinafter called the Canadian Company. If Bird was an employee, as the Board found, then its order should be affirmed. If, however, he was a partner or joint adventurer with the Canadian Company, then the petitioners…
2Cases cited12 opinions
- Burnet v. LeiningerSupreme Court of the United States · 1932
- United States v. Safety Car Heating & Lighting Co.Supreme Court of the United States · 1936
- Jackson v. HooperNew Jersey Court of Chancery · 1909
- Rossmoore v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
- Reynolds v. McMurrayCourt of Appeals for the Tenth Circuit · 1932
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3Cited by31 opinions
- Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957
- McRoberts v. PhelpsSupreme Court of Pennsylvania · 1958
- Commissioner of Internal Revenue v. WhitneyCourt of Appeals for the Second Circuit · 1948
- Resource Ventures, Inc. v. Resources Management International, Inc.District Court, D. Delaware · 1999
- Satellite Financial Planning Corp. v. First National BankDistrict Court, D. Delaware · 1986
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