Legal Opinion
The Steel Improvement and Forge Company v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided March 5, 1963No. 14800PublishedCited by 30 opinions
1Opinion of the Court
JOHN W. PECK, District Judge.
The record in this case presents a complicated factual pattern of financial negotiation culminating in a contract. However, that contract, from which the questions here at issue arose, is itself comparatively free from complexity. The petitioning Ohio corporation thereby contracted to sell its fully owned Canadian subsidiary (Canadian Steel Improvement Limited of Etobicoke, Ontario) to High Duty Alloys (Canada) Limited, which was a Canadian affiliate of Hawker Siddley Group Limited; these companies will be herein referred to as Canadian Steel, High Duty and Hawker…
2Cases cited6 opinions
- Moore v. CommissionerCourt of Appeals for the Seventh Circuit · 1941
- Rupe Investment Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- De Guire v. HigginsCourt of Appeals for the Second Circuit · 1947
- Christensen v. CommissionerUnited States Tax Court · 1959
- Wilson v. CommissionerUnited States Tax Court · 1957
1 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Waterman Steamship Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- J. E. Casner and Una Casner v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Waterman S.S. Corp. v. CommissionerUnited States Tax Court · 1968
- Frelbro Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- H. H. Robertson Co. v. CommissionerUnited States Tax Court · 1972
25 more not listed; retrieve them via the Exa API.