Legal Opinion

Commissioner of Internal Revenue v. Pacific Affiliate, Inc., a Corporation, Pacific Affiliate, Inc., a Corporation v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided July 20, 1955No. 14111_1PublishedCited by 17 opinions

1Per curiam

This is an appeal from a decision of the Tax Court, 18 T.C. 1175, in a case involving the excess profits tax statute. The Court sustained certain of the Commissioner’s deficiency assessments and overruled others. Both the taxpayer and the Commissioner have appealed.

The decision below was by the full membership of the Court and was without dissent except as to one relatively minor matter. It represents a well-considered effort to resolve points all of which are debatable. We are not persuaded that the Court was wrong in any particular.

One matter, however, should be noticed specifically. A…

2Cases cited4 opinions

  1. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  2. Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
  3. Lewyt Corp. v. CommissionerSupreme Court of the United States · 1955
  4. Stern Bros. & Co. v. CommissionerUnited States Tax Court · 1951

3Cited by17 opinions

  1. J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
  2. Motors Insurance v. United StatesUnited States Court of Claims · 1976
  3. Russell Manufacturing Company v. United StatesUnited States Court of Claims · 1959
  4. American Enka Corp. v. CommissionerUnited States Tax Court · 1958
  5. Luckman v. CommissionerUnited States Tax Court · 1971

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