Legal Opinion
Elizabeth N. B. Ferro v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided March 20, 1957No. 12032_1PublishedCited by 71 opinions
1Opinion of the Court
STALEY, Circuit Judge.
This petition for review presents for our consideration another of the countless factual situations which give rise to the question of whether a certain redemption of stock constitutes a constructive dividend under Section 115(g) of the Internal Revenue Code of 1939.
David A. Ferro (hereinafter called “petitioner”) and his wife, Elizabeth N. B. Ferro, duly filed a joint income tax return for 1950. 1 The Commissioner of Internal Revenue determined a deficiency of $7,692.18 in their return on the basis of the following facts:
Montgomery, Inc., a Pennsylvania corporation,…
2Cases cited24 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- United States v. Boston & Maine RailroadSupreme Court of the United States · 1929
19 more not listed; retrieve them via the Exa API.
3Cited by71 opinions
- Joseph R. Holsey and Eleanor T. Holsey v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Yelencsics v. CommissionerUnited States Tax Court · 1980
- Television Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- United States v. John H. FewellCourt of Appeals for the Fifth Circuit · 1958
- Heman v. CommissionerUnited States Tax Court · 1959
66 more not listed; retrieve them via the Exa API.