Legal Opinion
American Liberty Pipe Line Co. v. Commissioner
Court of Appeals for the Fifth Circuit
Decided July 14, 1944No. 10947PublishedCited by 2 opinions
1Opinion of the Court
HUTCHESON, Circuit Judge.
Another “undistributed net income credit”1 2case, the taxpayer claimed, and the commissioner denied that it was entitled to “the credit provided in Sec. 26(c) relating to contracts restricting dividends”.2 The Tax Court was of the opinion that taxpayer had failed to prove the existence and execution by the taxpayer, before May 1, 1936, of the written contract required by the Statute, and that the earnings were paid in discharge of a debt incurred prior to that date. In an opinion3 fully setting out, reviewing and analyzing the facts,4 *874all of which are undisputed, it…
2Cases cited9 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Helvering v. Credit Alliance Corp.Supreme Court of the United States · 1942
- Helvering v. Ohio Leather Co.Supreme Court of the United States · 1942
- C. C. Clark, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1942
- Florence Cotton Mills v. CommissionerCourt of Appeals for the Fifth Circuit · 1942
4 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Postal Mut. Indemnity Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
- Hercules Gasoline Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945