Legal Opinion
Estate of Leonard E. Whitlock, Deceased, Cross-Appellants v. Commissioner of Internal Revenue, Cross-Appellee
Court of Appeals for the Tenth Circuit
Decided May 22, 1974No. 73-1497, 73-1498PublishedCited by 23 opinions
1Opinion of the Court
SETH, Circuit Judge.
This is an appeal and cross-appeal which concern the taxation of stockholders of a controlled foreign corporation, which was also a foreign personal holding company. The issue centers on the question whether increases in earnings invested in United States property (section 951(a)(1)(B), Int.Rev.Code of 1954) by Whitlock Oil Services, Inc. should be included in taxpayers’ gross income. The Commissioner assessed deficiencies based on increases in such earnings so invested. The Tax Court held that the increases should not be included by reason of section 951(d). The opinion…
2Cases cited16 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
11 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- United Telecommunications, Inc. (Formerly United Utilities, Incorporated) v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1978
- Dow Chemical Co. v. Commissioner of RevenueMassachusetts Supreme Judicial Court · 1979
- Vetco, Inc. v. CommissionerUnited States Tax Court · 1990
- Estate of Whitlock v. CommissionerCourt of Appeals for the Tenth Circuit · 1976
- Edward J. Prescott and Wanda D. Prescott v. Commissioner of Internal Revenue, L. W. Simpson and Shirley Simpson v. United StatesCourt of Appeals for the Eighth Circuit · 1977
18 more not listed; retrieve them via the Exa API.