Legal Opinion
Frelbro Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided April 1, 1963No. 27587_1PublishedCited by 21 opinions
1Opinion of the Court
HAYS, Circuit Judge.
Petitioner seeks review of a decision of the Tax Court which upheld the Commissioner’s determination that petitioner was liable for personal holding company surtax for the year 1952. We reverse.
We shall first briefly summarize the circumstances which were held to have made petitioner liable to taxation as a personal holding company.
Until July 1952 Frelbro Corporation owned all the stock in Brown-Longyear Motors, Inc. In July 1952 John Longyear exercised an option which he had had for some time to purchase 51 % of the Brown-Longyear stock. In connection with this stock…
2Cases cited30 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Brown v. HelveringSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
- Rutkin v. United StatesSupreme Court of the United States · 1952
- Healy v. CommissionerSupreme Court of the United States · 1953
25 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Allied Fidelity Corp. v. CommissionerUnited States Tax Court · 1976
- Clarksdale Rubber Co. v. CommissionerUnited States Tax Court · 1965
- Commissioner of Internal Revenue v. Carl L. Danielson and Pauline S. Danielson, Commissioner Ofinternal Revenue v. Helen P. Sherman, Commissioner Ofinternal Revenue v. Estate of Jacob F. Schaffner, Deceased, Elizabeth Schaffner and Erwin Marsch, Executors, and Elizabeth Schaffner, Commissionerof Internal Revenue v. Hugh E. McLennan and Katherine McLennanCourt of Appeals for the Third Circuit · 1967
- Comtel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Hoffman Motors Corp. v. United StatesCourt of Appeals for the Second Circuit · 1973
16 more not listed; retrieve them via the Exa API.