Legal Opinion

Bond Auto Loan Corp. v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided January 16, 1946No. 13072PublishedCited by 7 opinions

1Opinion of the Court

WOODROUGH, Circuit Judge.

This is a petition to review a decision of the Tax Court redetermining deficiencies in personal holding company surtaxes imposed by the Commissioner of Internal Revenue.

The sole question is whether the Bond Auto Loan Corporation was a personal holding company during the taxable years ending April 30, 1939, and April 30, 1940, and was, therefore, subject to surtaxes for those years under Revenue Act 1938, and the Internal Revenue Code. The applicable provisions of the Revenue Act of 1938 provide :

Revenue Act of 1938, c. 289:

“Sec. 401. Surtax on personal holding…

2Cases cited3 opinions

  1. Girard Inv. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1941
  2. Noteman v. WelchCourt of Appeals for the First Circuit · 1939
  3. Workingmen's Loan Ass'n v. United StatesCourt of Appeals for the First Circuit · 1944

3Cited by7 opinions

  1. General American Life Ins. Co. v. CommissionerUnited States Tax Court · 1956
  2. Western Credit Co. v. CommissionerUnited States Tax Court · 1962
  3. General American Life Ins. Co. v. CommissionerUnited States Tax Court · 1956
  4. Lowenstein v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1946
  5. Lyner v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1946

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