Legal Opinion
Emeloid Co., Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided May 10, 1951No. 10337_1PublishedCited by 17 opinions
1Opinion of the Court
STALEY, Circuit Judge.
We are asked to decide whether sums borrowed by a corporation for the purchase of single-premium life insurance policies on the lives' of its two principal stockholder-officers constitute “borrowed invested capital” within the meaning of Section 719 of the World War II Excess Profits Tax Act, 1 26 U.S.C.A. § 719. The taxable year in question is the fiscal year ending June 30, 1944.
The basic facts are not in dispute; the only controversy is over the inferences or conclusions to be drawn therefrom. Petitioner is a New Jersey corporation engaged 1 in the manufacture and…
2Cases cited5 opinions
- Hart-Bartlett-Sturtevant Grain Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1950
- Commissioner of Internal Revenue v. SniteCourt of Appeals for the Seventh Circuit · 1949
- Hoover Steel Ball Co. v. Schaefer Ball Bearings Co.New Jersey Court of Chancery · 1919
- Borg v. International Silver Co.District Court, S.D. New York · 1926
- Fischer v. CommissionerUnited States Tax Court · 1947
3Cited by17 opinions
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
- Mountain State Steel Foundries, Inc., and v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1960
- Babcock & Wilcox Co. v. Pedrick. Babcock & Wilcox Tube Co. v. PedrickCourt of Appeals for the Second Circuit · 1954
- Motor Fuel Carriers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1977
- Gazette Pub. Co. v. SelfDistrict Court, E.D. Arkansas · 1952
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