Legal Opinion

M. C. Parrish & Co. v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided February 14, 1945No. 11171PublishedCited by 22 opinions

1Opinion of the Court

HOLMES, Circuit Judge.

The Tax Court sustained deficiencies assessed by the Commissioner with respect to petitioner’s income and excess profits tax returns for the calendar years 1937, 1939, and 1940. The decisive question upon review is whether profits, realized by petitioner through the purchase of non-interest-bearing treasuring warrants of the State of Texas at a discount and holding them until paid, were exempt from gross income as interest on state obligations under Section 22(b) (4) of the Revenue Act of 1936.

During the depression years following 1930 the State of Texas, finding its…

2Cases cited4 opinions

  1. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
  2. United States Trust Co. of New York v. AndersonCourt of Appeals for the Second Circuit · 1933
  3. Holley v. United StatesCourt of Appeals for the Sixth Circuit · 1942
  4. Daniel Bros. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1928

3Cited by22 opinions

  1. Lawrence v. CommissionerUnited States Tax Court · 1957
  2. Brown v. CommissionerUnited States Tax Court · 1961
  3. George Slaff v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  4. Edward T. And Isabel J. Lysek v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
  5. Kenneth R. Groves and Peggy L. Groves v. United StatesCourt of Appeals for the Fifth Circuit · 1976

17 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API