Legal Opinion
Pepi, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided September 7, 1971No. 357, Docket 34678PublishedCited by 9 opinions
1Opinion of the Court
LUMBARD, Circuit Judge:
PEPI, Inc. appeals from a decision of the Tax Court, 52 T.C. 854 (1969) (Mulroney, J.), which held that the petitioner’s predecessor corporation, Philips Electronics, Inc. (Electronics) was not entitled to certain tax deductions in its 1958 and 1959 returns. Electronics had taken the deductions based on a $2,133,-250.03 loss carryover that it had acquired as a result of a merger between its predecessor corporations, Philip Electronics, Inc. (Old Philips) and A. Hollander & Son, Inc. The Tax Court held that since the merger had been undertaken for the principal purpose…
2Cases cited8 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Charles Oran Mensik and Mary Mensik v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- Henry Van Hummell, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1966
- J. T. Slocomb Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
3 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- D'Arcy-MacManus & Masius, Inc. v. CommissionerUnited States Tax Court · 1975
- Linda F. Wilson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974
- Bay Sound Transportation Co. v. United StatesDistrict Court, S.D. Texas · 1972
- Gary Devore v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
- Herbert G. Whyte v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
4 more not listed; retrieve them via the Exa API.