Legal Opinion
Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, Cross
Court of Appeals for the Ninth Circuit
Decided October 5, 1966No. 20159-20174_1PublishedCited by 83 opinions
1Opinion of the Court
HAMLEY, Circuit Judge:
The Commissioner of Internal Revenue filed these consolidated petitions for review of decisions of the Tax Court involving federal income taxes for fiscal years ending in 1955, 1956, 1957 and 1958. The taxpayers, Seaboard Finance Company and fourteen of its subsidiaries (Seaboard), all engaged in the small loan business, filed cross petitions.
The Tax Court had the problem of determining how much, if any, of the amount paid by Seaboard in acquiring other small loan businesses was attrib utable to good will or other elements of value for which depreciation deductions are…
2Cases cited16 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Thrifiticheck Service Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Commissioner of Internal Revenue v. Maurice L. KillianCourt of Appeals for the Fifth Circuit · 1963
11 more not listed; retrieve them via the Exa API.
3Cited by83 opinions
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
- Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
- Computing & Software, Inc. v. CommissionerUnited States Tax Court · 1975
- Winn-Dixie Montgomery, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Lucas v. CommissionerUnited States Tax Court · 1972
78 more not listed; retrieve them via the Exa API.