Legal Opinion
Delaware Realty & Investment Company v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided June 13, 1956No. 11852PublishedCited by 9 opinions
1Opinion of the Court
HASTIE, Circuit Judge.
In 1948 and 1949, petitioner, a Delaware corporation, was a personal holding company within the purview of the then effective Section 501 of the Internal Revenue Code of 1939, 26 U.S.C. 1952 ed. § 501. Its tax accounting was done on a cash and calendar year basis. For the year 1949, petitioner reported that it had incurred no liability for personal holding company surtax. However, the Commissioner substantially revised petitioner’s computation of its undistributed Sub-chapter A net income and thereby determined a surtax deficiency of $1,345,373.-36. The Tax Court…
2Cases cited4 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- White v. United StatesSupreme Court of the United States · 1938
- United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
3Cited by9 opinions
- Arc Realty Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1961
- Arc Realty Co. v. CommissionerUnited States Tax Court · 1960
- Litchfield Securities Corporation v. United StatesCourt of Appeals for the Second Circuit · 1963
- Arc Realty Company, a Corporation v. Commissioner of Internal Revenue, Arcadia Realty Company, a Corporation v. Commissioner of Internal Revenue, Lydiade Investment Trust, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
- Utility Trailer Manufacturing Company v. United StatesDistrict Court, S.D. California · 1962
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