Legal Opinion
Stern & Stern Textiles, Inc. (Successor in Interest to Huguet Fabrics Corporation) v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided February 2, 1959No. 24542-24545_1PublishedCited by 15 opinions
1Opinion of the Court
SWAN, Circuit Judge.
The petitioner seeks review of a decision of the Tax Court, reported in 26 T.C. 1000, holding that the doctrine of collateral estoppel precludes the taxpayer from litigating its claim to relief under § 722 (b) of the 1939 Code, as amended, 26 U.S. ‘C.A. Excess Profits Taxes, § 722(b), for its five fiscal years ending September 30, 1942 through 1946 inclusive.
Before reaching the merits of the appeal it is necessary to consider the Commissioner’s contention that this court lacks jurisdiction to review the Tax ■Court’s decision. The contention is based •on § 732(c), 26…
2Cases cited5 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Stern & Stern Textiles, Inc. v. CommissionerUnited States Tax Court · 1956
- The Crowell-Collier Publishing Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Huguet Fabrics Corp. v. CommissionerUnited States Tax Court · 1952
- George Kemp Real Estate Co. v. CommissionerCourt of Appeals for the Second Circuit · 1953
3Cited by15 opinions
- Bell v. CommissionerUnited States Tax Court · 1985
- Randolph v. CommissionerUnited States Tax Court · 1980
- Lea, Inc. v. CommissionerUnited States Tax Court · 1978
- Headline Publications, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1959
- United States Rubber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
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