Legal Opinion
Perthur Holding Corp. v. Commissioner of Int. Rev.
Court of Appeals for the Second Circuit
Decided November 7, 1932No. 23PublishedCited by 7 opinions
1Opinion of the Court
L. HAND, Circuit Judge.
The taxpayer was a corporation with an authorized capital of $260,000, none of which had been issued. In December, 1925, it issued $250,000 of its shares to one, Kuttroff, in exchange for land in New York which at the time was worth that amount, and which it sold in 1926 at a small loss. This is deducted in its return for that year, but the Commissioner struck out the deduction, and in its place assessed as a deficiency, a tax levied upon the difference between the proceeds of the sale in 1926 and the value of the land oh March 1, 1913, Kuttroff having bought before…
2Cases cited13 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Blodgett v. HoldenSupreme Court of the United States · 1927
- Child Labor Tax CaseSupreme Court of the United States · 1922
8 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Darcy v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
- King v. United StatesCourt of Appeals for the Fourth Circuit · 1935
- Ballester v. Descartes, Treasurer of Puerto RicoCourt of Appeals for the First Circuit · 1950
- TW Phillips, Jr., Inc. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1933
- Wilson Coal Land Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1937
2 more not listed; retrieve them via the Exa API.