Legal Opinion
Pridemark, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided April 23, 1965No. 9707PublishedCited by 24 opinions
1Opinion of the Court
SOBELOFF, Circuit Judge:
This petition for review principally challenges the determination of the Tax Court1 sustaining the Commissioner’s application of the “reincorporation” doctrine, and his denial of an exemption from taxation to proceeds from the sale of certain sales contracts by liquidating corporations. The facts are fully set forth in Judge Pierce’s opinion and we shall here state only those we deem essential.
Pridemark, Inc., one of the petitioners in this case, was incorporated in 1946 under the laws of Maryland, with a paid-in capital of $6,000 represented by 5,000 shares of common…
2Cases cited12 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
7 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Estate of Bernard H. Stauffer, Bonnie H. Stauffer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
- National Labor Relations Board v. Wheeling Electric Company, National Labor Relations Board v. Wheeling Electric Power CompanyCourt of Appeals for the Fourth Circuit · 1971
- United States v. MortonCourt of Appeals for the Eighth Circuit · 1968
- United States v. Mountain States Mixed Feed Company, Joseph Pepper, Marvin Pepper, and Freeman PepperCourt of Appeals for the Tenth Circuit · 1966
- R. A. Babcock and Norma L. Babcock v. V. Lee PhillipsCourt of Appeals for the Tenth Circuit · 1967
19 more not listed; retrieve them via the Exa API.