Commissioner of Internal Revenue v. Keller
Court of Appeals for the Seventh Circuit
These petitions involve income and profils taxes for the years 1920,1921,1922, and 1923 in respective amounts of $1,816.90, $2,496.-50, $456.06, and $689.16, pins interest.
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These petitions involve income and profils taxes for the years 1920,1921,1922, and 1923 in respective amounts of $1,816.90, $2,496.-50, $456.06, and $689.16, pins interest. The statutes involved are Revenue Act of 1926, c. 27, 44 Stat. 61, § 280 (a) (1), (f), 26 USCA § 1069 (a) (1), (f); and Act of June 28, 1919, c. 32, Illinois R. S. (Cahill’s 1929), § 23, (2), which, are set forth in the margin.1 The causes were consolidated for the purpose of hearings and decisions, and the questions presented arise over the transfer of certain assets to respondents by Wilson Avenue Garage Company,…
1Opinion of the Court
SPARKS, Circuit Judge.
It is contended by tbe government that ■the Board of Tax Appeals erred: (1) In not holding that the distribution o £ assets of the company to respondents, prior to the sale of the company’s capital stock, created a condition of insolvency which made respondents, as transferees under- the trust fund doctrine, liable for the taxes involved in those proceedings, as recognized in McDonald, Receiver, v. Williams, 174 U. S. 397, 19 S. Ct. 743, 43 L. Ed. 1022; Hollins v. Brierfield Coal & iron Co., 150 U. S. 371, 14 S. Ct. 127, 37 L. Ed. 1113; Ratcliff v. Clendenin (C. C. A.)…
2Cases cited13 opinions
- Hollins v. Brierfield Coal & Iron Co.Supreme Court of the United States · 1893
- Weiss v. WeinerSupreme Court of the United States · 1929
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Sanger v. UptonSupreme Court of the United States · 1875
- McDonald v. WilliamsSupreme Court of the United States · 1899
8 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Kozak v. RETIREMENT BOARD OF FIREMEN'S ANNUITY AND BENEFIT FUNDIllinois Supreme Court · 1983
- Scott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1941
- Ruth Halle Rowen, Ethel F. Halle, and Edward Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- Pearlman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1946
- Rowen v. CommissionerUnited States Tax Court · 1952
15 more not listed; retrieve them via the Exa API.