Legal Opinion
Garlock, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 12, 1973No. 60, Docket 72-2108PublishedCited by 24 opinions
1Opinion of the Court
OAKES, Circuit Judge:
This is an appeal from a decision of the Tax Court, 58 T.C. 423 (1972) deter mining deficiencies in income tax from the appellant, Garlock, Inc. (Garlock), for its fiscal year ending December 27, 1964, in the sum of $93,335.83, and that-ending December 26, 1965, in the sum of $27,061.49. These determinations were made on the basis that Garlock, S.A. (S.A.), a Panamanian corporation and originally a wholly owned subsidiary of appellant, was a “controlled foreign corporation” (CFC) within the meaning of § 957(a) of the Internal Revenue Code of 1954, as amended, and against…
2Cases cited12 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Helvering v. GregoryCourt of Appeals for the Second Circuit · 1934
- Heiner v. MellonSupreme Court of the United States · 1938
- Ripley v. StorerNew York Court of Appeals · 1956
7 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
- R.E. Dietz Corporation v. United StatesCourt of Appeals for the Second Circuit · 1991
- Dow Chemical Co. v. Commissioner of RevenueMassachusetts Supreme Judicial Court · 1979
- Davidson Pipe Co. v. Laventhol & HorwathDistrict Court, S.D. New York · 1988
- Estate of Leonard E. Whitlock, Deceased, Cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Tenth Circuit · 1974
19 more not listed; retrieve them via the Exa API.