Legal Opinion

Kann v. Commissioner of Internal Revenue. Kann's Estate v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided February 15, 1954No. 11066, 11067PublishedCited by 137 opinions

1Opinion of the Court

McLAUGHLIN, Circuit Judge.

We are asked to review two decisions of the Tax Court, 18 T.C. 1032, upholding certain income tax deficiencies and fraud penalties for the years 1936 through 1941. Petitioners are W. L. Kann and Stella H. Kann, his wife, and the representatives of Gustave H. Kann, deceased.1

A summary of the leading facts as stipulated and found follows. G. H. and W. L. Kann were brothers. During all the years in question both were shareholders, directors and officers of Pittsburgh Crushed Steel Company (hereafter called PCS), a Pennsylvania corporation, G. H. Kann being the president…

2Cases cited8 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Commissioner v. WilcoxSupreme Court of the United States · 1946
  3. Rutkin v. United StatesSupreme Court of the United States · 1952
  4. Quock Ting v. United StatesSupreme Court of the United States · 1891
  5. United States v. LewisSupreme Court of the United States · 1951

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3Cited by137 opinions

  1. James v. United StatesSupreme Court of the United States · 1961
  2. Otsuki v. CommissionerUnited States Tax Court · 1969
  3. Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
  4. Federbush v. CommissionerUnited States Tax Court · 1960
  5. Jerome H. Moore and Mildred v. Moore v. United States of America, Jerome H. Moore and Mildred v. Moore v. United StatesCourt of Appeals for the Fourth Circuit · 1966

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