Legal Opinion

United Light & Power Co. v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided July 12, 1939No. 6890PublishedCited by 8 opinions

1Opinion of the Court

EVANS, Circuit Judge.

Did the taxpayer’s (petitioner herein) exchange of securities constitute a “statutory reorganization” so that the profits, realized therefrom were non-taxable? This is the question for our determination on this appeal.

The Board affirmed the Commissioner’s determination of a deficiency income tax of $1,076,314.40 for the year 1928. - There is no dispute as to the amount, if the Board’s determination of liability be sound.

The Parties. The United Light and Power Company, petitioner-taxpayer, filed a consolidated tax return for the year 1928, for itself and subsidiaries, one…

2Cases cited28 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
  3. Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
  4. Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
  5. Groman v. CommissionerSupreme Court of the United States · 1937

23 more not listed; retrieve them via the Exa API.

3Cited by8 opinions

  1. Commissioner of Internal Revenue v. American Light & Traction Co.Court of Appeals for the Seventh Circuit · 1942
  2. Interstate Transit Lines v. Commissioner of Int. Rev.Court of Appeals for the Eighth Circuit · 1942
  3. Anheuser-Busch, Inc. v. HelveringCourt of Appeals for the Eighth Circuit · 1940
  4. Maine Steel, Inc. v. United StatesDistrict Court, D. Maine · 1959
  5. Tennessee, Alabama & Georgia Ry. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951

3 more not listed; retrieve them via the Exa API.

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