Legal Opinion

Mid-America Industries, Inc., a Delaware Corporation v. United States

Court of Appeals for the Eighth Circuit

Decided May 25, 1973No. 72-1515PublishedCited by 6 opinions

1Opinion of the Court

HEANEY, Circuit Judge.

The United States appeals from a decision of the trial court awarding taxpayers a refund of $36,561.04, plus interest, for corporate taxes paid under protest for calendar years 1964-1967. The sole issue on this appeal is whether the taxpayers constituted a “controlled group of corporations” under § 1563 of the Internal Revenue Code of 1954. 1

The Automotive, Inc. (Automotive), a closely held Delaware corporation, headquartered in Fort Smith, Arkansas, began business as a jobber of automobile parts in 1920. 2 By 1957, it had a number of branch offices located in various…

2Cases cited3 opinions

  1. Barton Naphtha Co. v. CommissionerUnited States Tax Court · 1971
  2. Superior Beverage Co. v. CommissionerUnited States Tax Court · 1972
  3. Mid-America Industries, Inc. v. United StatesDistrict Court, W.D. Arkansas · 1972

3Cited by6 opinions

  1. Central Transport, Inc. v. Central States, Southeast & Southwest Area Pension FundDistrict Court, E.D. Tennessee · 1986
  2. In Re Mushroom Transportation Co.United States Bankruptcy Court, E.D. Pennsylvania · 1988
  3. Tri-State Rubber & Equipment, Inc. v. Central States Southeast & Southwest Areas Pension FundDistrict Court, E.D. Michigan · 1987
  4. Crow-Burlingame Co. v. CommissionerUnited States Tax Court · 1976
  5. Crow-Burlingame Co. v. CommissionerUnited States Tax Court · 1976

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