Legal Opinion
Commissioner of Internal Revenue v. Chelsea Products, Inc
Court of Appeals for the Third Circuit
Decided June 24, 1952No. 10652, 10653PublishedCited by 106 opinions
1Opinion of the Court
STALEY, Circuit Judge.
The Commissioner of Internal Revenue has petitioned for a review of two decisions of the Tax Court. 1 The principal issue presented is whether Section 45 of the Internal Revenue Code, 26 U.S.C.A. § 45, authorizes the Commissioner to combine the net income of three corporations with that of taxpayer where all are owned by the same interests. We are in accord with the Tax Court’s conclusion that Section 45 was erroneously applied.
Between 1941 and 1944, taxpayer was engaged in the manufacture and sale of fans and blowers under the name of Chelsea Fan & Blower Co., Inc. 2…
2Cases cited7 opinions
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Asiatic Petroleum Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
- Advance MacHinery Exchange, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- GUR Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1941
- Jones v. Jefferson Standard Life InsuranceSupreme Court of the United States · 1935
2 more not listed; retrieve them via the Exa API.
3Cited by106 opinions
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Achiro v. CommissionerUnited States Tax Court · 1981
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Riss v. CommissionerUnited States Tax Court · 1971
- Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
101 more not listed; retrieve them via the Exa API.