Anthony P. Miller, Inc. v. Commissioner of Int. Rev.
Court of Appeals for the Third Circuit
1Opinion of the Court
GOODRICH, Circuit Judge.
In asking reversal of a decision by the Tax Court 1 the taxpayer corporation tenders us six issues. Five of them present questions of fact; one presents a question of law. The question of law will be treated first.
The question of law is narrow but interesting. It has to do with Section 24(c) of the Internal Revenue Code, 26 U.S.C.A Int.Rev.Code, § 24(c), dealing with situations in which deductions are not allowed under certain circumstances. The Section precludes a deduction if the three conditions set out in it are all met. 2 There is no dispute that two of the…
2Cases cited9 opinions
- Musselman Hub-Brake Co. v. Com'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- PG Lake, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
- Stebbins v. North Adams Trust Co.Massachusetts Supreme Judicial Court · 1922
- Gaunt v. Alabama Bound Oil & Gas Co.Court of Appeals for the Eighth Circuit · 1922
- Dickson v. TaylorSupreme Court of Oklahoma · 1923
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3Cited by45 opinions
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Fountain v. CommissionerUnited States Tax Court · 1973
- Time Oil Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Geiger & Peters, Inc. v. CommissionerUnited States Tax Court · 1957
- Burton Swartz Land Corp v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952
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