Legal Opinion
Canister Co. v. Commissioner
Court of Appeals for the Third Circuit
Decided January 20, 1948No. 9422PublishedCited by 12 opinions
1Opinion of the Court
GOODRICH, Circuit Judge.
The taxpayer’s present controversy with the Commissioner of Internal Revenue presents a question under the sometimes difficult excess profits tax provisions. Int. Rev.Code, § 710 et seq., 54 Stat. 975-998, 26 U.S.C.A. Int.Rev.Code, § 710 et seq. But the immediate item of dispute presents a single issue which can be simply and clearly stated. The taxpayer makes a claim, disputed by the Commissioner, under § 719 of the Internal Revenue Code which has to do with “borrowed invested capital”. If it can maintain its claim, the settlement of the dispute becomes automatic; if…
2Cases cited7 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
- Journal Publishing Co. v. CommissionerUnited States Tax Court · 1944
- Flint Nortown Theatre Co. v. CommissionerUnited States Tax Court · 1945
- Lincoln Electric Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1947
2 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- National Bank of Commerce v. CommissionerUnited States Tax Court · 1951
- Bernard Realty Co. v. United StatesCourt of Appeals for the Seventh Circuit · 1951
- CL Downey Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1949
- Jackson Finance & Thrift Co. v. CommissionerUnited States Tax Court · 1957
- Burford-Toothaker Tractor Co. v. United StatesDistrict Court, M.D. Alabama · 1958
7 more not listed; retrieve them via the Exa API.