Legal Opinion

The Guarantee Title and Trust Co. v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided February 18, 1963No. 14838_1PublishedCited by 16 opinions

1Opinion of the Court

WILLIAM E. MILLER, District Judge.

This case comes before us on the petition of the Taxpayer, The Guarantee Title & Trust Company, an Ohio corporation, to review the decision of the Tax Court that the Taxpayer was required to accrue as income for federal income tax purposes, as of the end of its taxable years 1955 and 1956, certain amounts reflected on its books in excess of the compensation actually paid to it in those years by The Bowery Savings Bank pursuant to a mortgage servicing contract.

The Bowery, a mutual savings institution located in New York City, invests in mortgage loans on real…

2Cases cited8 opinions

  1. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  2. Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
  3. Commissioner v. HansenSupreme Court of the United States · 1959
  4. The Cappel House Furnishing Company v. United StatesCourt of Appeals for the Sixth Circuit · 1957
  5. Bauer Bros. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1931

3 more not listed; retrieve them via the Exa API.

3Cited by16 opinions

  1. Bankers Union Life Ins. Co. v. CommissionerUnited States Tax Court · 1974
  2. Gunderson Bros. Engineering Corp. v. CommissionerUnited States Tax Court · 1964
  3. Harmont Plaza, Inc. v. CommissionerUnited States Tax Court · 1975
  4. Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1974
  5. Etheridge & Vanneman, Inc. v. CommissionerUnited States Tax Court · 1963

11 more not listed; retrieve them via the Exa API.

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