Consolidated Premium Iron Ores, Ltd. v. Commissioner
United States Tax Court
1. Where individual petitioners at all times acted as agents or representatives of certain corporations existing or to be formed, they were not liable personally or in their individual capacity for income arising from the bargain purchase of stock of one corporation by a second corporation. 2. Under the Tax Convention and Protocol between the United States and Canada, where a Canadian corporation did not engage in trade or business within the United States and did not have a…
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1. Where individual petitioners at all times acted as agents or representatives of certain corporations existing or to be formed, they were not liable personally or in their individual capacity for income arising from the bargain purchase of stock of one corporation by a second corporation. 2. Under the Tax Convention and Protocol between the United States and Canada, where a Canadian corporation did not engage in trade or business within the United States and did not have a "permanent establishment" therein, such corporation is not liable to the United States for taxes on the income of such…
1Opinion of the Court
Consolidated Premium Iron Ores Limited, et al., * Petitioners, v. Commissioner of Internal Revenue, Respondent
Consolidated Premium Iron Ores, Ltd. v. Commissioner
Docket Nos. 47893, 54352, 54396
United States Tax Court
28 T.C. 127; 1957 U.S. Tax Ct. LEXIS 212;
April 23, 1957, Filed
Decisions will be entered under Rule 50.
1. Where individual petitioners at all times acted as agents or representatives of certain corporations existing or to be formed, they were not liable personally or in their individual capacity for income arising from the bargain purchase of stock of one corporation by a second…
2Cases cited8 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Helvering v. EubankSupreme Court of the United States · 1941
- Lewellyn v. Pittsburgh, B. & L. E. R.Court of Appeals for the Third Circuit · 1915
- Herbert v. RiddellDistrict Court, S.D. California · 1952
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