Legal Opinion
Richard M. Mills and Moise W. Mills v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided May 6, 1964No. 20467_1PublishedCited by 8 opinions
1Opinion of the Court
MARIS, Circuit Judge.
These consolidated petitions to review three decisions of the Tax Court present the issue whether the common transaction in question qualifies as a nontaxable reorganization within the meaning of section 368(a) (1) (B) of the Internal Revenue Code of 1954, 26 U.S.C. § 368 (a) (1) (B).
The petitioners, three brothers, 1 who owned in equal shares all the stock of three small gas corporations, were negotiating early in 1954 to merge their corporations with seven other small gas corporations into one corporation. Before this proposed merger reached fruition, negotiations were…
2Cases cited4 opinions
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Turnbow v. CommissionerSupreme Court of the United States · 1961
- Julius Long Stern and Ellen v. Stern v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1954
- Mills v. CommissionerUnited States Tax Court · 1962
3Cited by8 opinions
- American Potash & Chemical Corporation v. The United StatesUnited States Court of Claims · 1968
- Arden S. Heverly and Sophia S. Heverly v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1980
- Eldon S. Chapman v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1980
- Reeves v. CommissionerUnited States Tax Court · 1979
- Pierson v. United StatesDistrict Court, D. Delaware · 1979
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