Legal Opinion

Foley Securities Corp. v. Commissioner

Court of Appeals for the Eighth Circuit

Decided October 11, 1939No. 11458PublishedCited by 15 opinions

1Opinion of the Court

SANBORN, Circuit Judge.

The taxpayer, a Minnesota corporation organized in 1928 and a “personal holding company” within the meaning of Section 351 of the Revenue Act of 1934, c. 277, 48 Stat. 680, 751, 26 U.S.C.A. § 331 (which provides for a surtax upon the “undistributed adjusted net income” of such a corporation), has petitioned for a review of a decision of the Board of Tax Appeals (38 B.T.A. 1036) which sustained a deficiency of $4,100.59 in the surtaxes of the petitioner for the year 1934.

The facts are stipulated. The taxpayer at the beginning of 1934 had an operating deficit of…

2Cases cited45 opinions

  1. Village of Euclid v. Ambler Realty Co.Supreme Court of the United States · 1926
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Church of the Holy Trinity v. United StatesSupreme Court of the United States · 1892
  4. Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
  5. Steward MacHine Co. v. DavisSupreme Court of the United States · 1937

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

3Cited by15 opinions

  1. Helvering v. Rebsamen Motors, Inc.Court of Appeals for the Eighth Circuit · 1942
  2. Edward C. Heard and Cora L. Heard v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
  3. Van Norman Co. v. WelchCourt of Appeals for the First Circuit · 1944
  4. Pembroke Realty & Securities Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1941
  5. Haffenreffer Brewing Co. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1940

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API