Legal Opinion
Kessmar Construction Company v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided August 28, 1964No. 18840_1PublishedCited by 22 opinions
1Opinion of the Court
DUNIWAY, Circuit Judge.
Sixteen corporations seek review of a decision of the Tax Court. The sole question is whether the Commissioner of Internal Revenue, acting under the provisions of section 269 of the Internal Revenue Code of 1954, (26 U.S.C. § 269), properly determined that each corporation was acquired by its stockholders (each had the same stockholdei's) for the “principal purpose” of “ * * * evasion or avoidance of Federal income tax by securing the benefit of a deduction, credit, or other allowance which such person or corporation would not otherwise enjoy * * Having so determined,…
2Cases cited5 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Wood v. United StatesSupreme Court of the United States · 1842
- Gillette's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1950
- National Labor Relations Board v. National Seal Corp.Court of Appeals for the Second Circuit · 1942
- Kessmar Constr. Co. v. CommissionerUnited States Tax Court · 1963
3Cited by22 opinions
- James A. And Isabelle Carroll v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
- Bobsee Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1969
- Northwest Acceptance Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
- Lewisville Inv. Co. v. CommissionerUnited States Tax Court · 1971
- Brumley-Donaldson Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
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