Legal Opinion
Commissioner of Internal Rev. v. Western Union Tel. Co.
Court of Appeals for the Second Circuit
Decided March 23, 1944No. 57, 141PublishedCited by 28 opinions
1Opinion of the Court
AUGUSTUS N. HAND, Circuit Judge.
The Commissioner has assessed against the respondents herein as transferees of certain corporations of which they were stockholders liability in respect to unpaid income taxes of the respective transferor corporations. Liability is predicated upon Section 311 of the Revenue Acts of 1928 and 1932, 26 U.S.C.A. Int.Rev.Code, § 311.
Several years before income taxes had been authorized by the Sixteenth Amendment the taxpayers primarily liable leased all of their properties for terms ranging from 99 to 999 years. Western Union was lessee of six of the original…
2Cases cited22 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Higgins v. SmithSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Phillips v. CommissionerSupreme Court of the United States · 1931
17 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Ruth Halle Rowen, Ethel F. Halle, and Edward Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- Pearlman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1946
- Pelham Hall Co. v. HassettCourt of Appeals for the First Circuit · 1945
- United States v. Ella Swaab Behrens, Individually, and as of Leo F. BehrensCourt of Appeals for the Second Circuit · 1956
23 more not listed; retrieve them via the Exa API.