Legal Opinion
Helm & Smith Syndicate v. Com'r of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided June 22, 1943No. 10352PublishedCited by 12 opinions
1Opinion of the Court
DENMAN, Circuit Judge.
Petitioner seeks a review of an order of the United States Board of Tax Appeals, now named Tax Court of the United States, and hereinafter called the Tax Court, determining that appellant’s income- and excess profits taxes for the calendar-year 1938 should be computed by treating-appellant as an “association” within the-meaning-of Section 901(a) of the Revenue Act of 1938, 26 U.S.C.A. Int.Rev.Code, §: 3797(a), and therefore taxable as a corporation.
Appellant is an unincorporated group-which in 1938 had three successive forms, of organization. The first was under a trust…
2Cases cited3 opinions
- Commissioner of Internal Revenue v. GerstleCourt of Appeals for the Ninth Circuit · 1938
- Commissioner of Internal Revenue v. Rector & DavidsonCourt of Appeals for the Fifth Circuit · 1940
- Thrash Lease Trust v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1938
3Cited by12 opinions
- Hynes v. CommissionerUnited States Tax Court · 1980
- John Province 1 Well v. CommissionerUnited States Tax Court · 1961
- Arthur Rohman and Jevne Shepherd Rohman, as Co-Trustees of Ida S. Shepherd Trust v. United StatesCourt of Appeals for the Ninth Circuit · 1960
- United States v. L. H. Stierwalt and Helen H. StierwaltCourt of Appeals for the Tenth Circuit · 1961
- Guaranty Employees Association v. United StatesCourt of Appeals for the Fifth Circuit · 1957
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