Legal Opinion
Commissioner of Internal Revenue v. Tennessee Co.
Court of Appeals for the Third Circuit
Decided March 28, 1940No. 7269PublishedCited by 11 opinions
1Opinion of the Court
CLARK, Circuit Judge.
The case at bar is one of first impression, 402 C.C.H. para. 1684B, and cf. Hughes & Co. v. Commissioner, 8 Cir., 109 F.2d 720, involving the surtax imposed on personal holding companies by the Revenue Act of 1934, § 351, 26 U.S.CA.Int.Rev.Acts, page 757. That measure, as we had recent occasion to observe in Sanford Corp. v. Commissioner, 3 Cir., 106 F.2d 882, cer-tiorari denied, February 5, 1940, 60 S.Ct. 513, 84 L.Ed. -, is directed to the more efficient elimination of certain methods of tax avoidance. The employment of one of these methods is clearly discernible in the…
2Cases cited4 opinions
- United Business Corp. of Am. v. CommissionerUnited States Board of Tax Appeals · 1930
- In re HopsonNew York Court of Chancery · 1831
- Sanford Corporation v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1939
- Robert Hughes & Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1940
3Cited by11 opinions
- Hamlen v. WelchCourt of Appeals for the First Circuit · 1940
- Westor Theatres, Inc. v. Warner Bros. Pictures, Inc.District Court, D. New Jersey · 1941
- Wheat v. United StatesDistrict Court, S.D. Texas · 1973
- Haffenreffer Brewing Co. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1940
- Burford-Toothaker Tractor Company, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1959
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