Legal Opinion
United States v. Erie Forge Co.
Court of Appeals for the Third Circuit
Decided September 28, 1951No. 10409PublishedCited by 27 opinions
1Opinion of the Court
KLALODNER, Circuit Judge.
Is a delinquency penalty assessed by the Commissioner of Internal' Revenue' under Section 291 of the Internal Revenue Code 1 because of taxpayer’s failure tó file excess-profits tax returns as required by the Vinson Act 2 a “deficiency” under Section 271(a) of the Code, 3 rendering applicable the provisions of Section' 272(a) of the Code ? 4
That is the primary issue presented by the instant appeal by the United States of America, plaintiff below, from an order of the District Court denying its motion for summary judgment and granting the defendant-taxpayer’s motion to…
2Cases cited6 opinions
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- United States v. MichelSupreme Court of the United States · 1931
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- Commissioner of Internal Revenue v. Erie Forge Co.Court of Appeals for the Third Circuit · 1948
- Jenkins v. SmithCourt of Appeals for the Second Circuit · 1938
1 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Fairmont Aluminum Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
- Hannan v. CommissionerUnited States Tax Court · 1969
- Estate of Di Rezza v. CommissionerUnited States Tax Court · 1982
- Ralph C. Granquist, District Director of Internal Revenue for the District of Oregon v. Margaret HacklemanCourt of Appeals for the Ninth Circuit · 1959
- United States v. Lawrence W. Berman, Mariln Berman, and Forex CorporationCourt of Appeals for the Sixth Circuit · 1987
22 more not listed; retrieve them via the Exa API.