Legal Opinion
McNaghten v. United States
United States Court of Claims
Decided January 11, 1937No. 42688, 42689PublishedCited by 8 opinions
1Opinion of the Court
LITTLETON, Judge.
Plaintiffs contend that the amounts distributed by the Holmby Corporation out of its earnings and profits, being distributions in complete liquidation of that corporation, all constituted a return of capital to the trustees of the Arthur Letts Trust for the reason that, under section 201 (c) of the Revenue Act of 1926 (44 Stat. 10, 11) they were in the nature of part payments in exchange for the stock upon which distributed and applied against and reduced the basis thereof in the trustees’ hands, a basis which had not been wholly recovered by the end of 1927. Plaintiffs…
2Cases cited6 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- Baltzell v. MitchellCourt of Appeals for the First Circuit · 1925
- Letts v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1936
- Abell v. TaitCourt of Appeals for the Fourth Circuit · 1929
- Letts v. CommissionerUnited States Board of Tax Appeals · 1934
1 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Commissioner of Internal Revenue v. HopkinsonCourt of Appeals for the Second Circuit · 1942
- Samuel C. Dysart and Alma R. Dysart v. The United StatesUnited States Court of Claims · 1965
- Welch v. SolomonCourt of Appeals for the Ninth Circuit · 1938
- Brown v. United StatesDistrict Court, E.D. Missouri · 1937
- Benfield v. United StatesUnited States Court of Claims · 1939
3 more not listed; retrieve them via the Exa API.