Legal Opinion
Hmw Industries, Inc. v. Rueben B. Wheatley, Commissioner of Finance, Government of the Virgin Islands
Court of Appeals for the Third Circuit
Decided September 25, 1974No. 74-1092PublishedCited by 14 opinions
1Opinion of the Court
opinion of the court
GARTH, Circuit Judge
This appeal 1 involves the proper income tax treatment of non-taxable subsidies granted under Act 224 of the Virgin Islands Session Laws (1957). The question presented is whether such subsidies (non-taxable when paid) reduce the basis of property acquired with the subsidy payment, so that upon liquidation and distribution of that property (from subsidiary to parent), the reduced property basis results in increased income and hence additional taxes to the parent. The answer to this question depends upon whether the non-taxable subsidies are to be…
2Cases cited8 opinions
- Ex Parte EndoSupreme Court of the United States · 1945
- Swayne & Hoyt, Ltd. v. United StatesSupreme Court of the United States · 1937
- Edwards v. Cuba RailroadSupreme Court of the United States · 1925
- Rafferty v. Smith, Bell & Co.Supreme Court of the United States · 1921
- George H. T. Dudley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
3 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Danbury, Inc. v. Anthony Olive, Director, Bureau of Internal Revenue, Government of the Virgin IslandsCourt of Appeals for the Third Circuit · 1987
- Chase Manhattan Bank, N.A. v. Government of the Virgin Islands, Bureau of Internal RevenueCourt of Appeals for the Third Circuit · 2002
- Gregory E. Miller and Doris D. Miller v. Leroy A. Quinn, Director of Internal RevenueCourt of Appeals for the Third Circuit · 1986
- Polychrome International Corp. v. KriggerCourt of Appeals for the Third Circuit · 1993
- Bartholomew v. District of Columbia Office of Tax & RevenueDistrict of Columbia Court of Appeals · 2013
9 more not listed; retrieve them via the Exa API.