Legal Opinion

M. F. Reddington Co. v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided December 2, 1942No. 11PublishedCited by 15 opinions

1Opinion of the Court

FRANK, Circuit Judge.

During the taxable year, Martin F. Reddington was president of taxpayer, a New York corporation, and owned 9,500 of the 18,000 shares of taxpayer’s common. stock. The remainder of the outstanding common stock of taxpayer was owned by Reddington’s daughter. Reddington owned the entire outstanding preferred stock of taxpayer, consisting of 2,500 shares. Taxpayer was originally a going concern engaged in the advertising business, but ceased active business upon retirement of Reddington in 1931. Taxpayer concedes that, during the taxable year, it was a personal holding…

2Cases cited4 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  3. Hoffman v. PalmerCourt of Appeals for the Second Circuit · 1942
  4. Commissioner of Internal Revenue v. Beck's EstateCourt of Appeals for the Second Circuit · 1942

3Cited by15 opinions

  1. Kaplan v. CommissionerUnited States Tax Court · 1953
  2. Sicanoff Vegetable Oil Corp. v. CommissionerUnited States Tax Court · 1957
  3. American Mfg. Co. v. CommissionerUnited States Tax Court · 1970
  4. United States Holding Co. v. CommissionerUnited States Tax Court · 1965
  5. Morris Investment Corp. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1946

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