Legal Opinion

Commissioner v. Levis' Estate

Court of Appeals for the Second Circuit

Decided May 5, 1942No. Nos. 97, 98PublishedCited by 7 opinions

1Opinion of the Court

SWAN, Circuit Judge.

During the taxable years in suit Carl Levis, now deceased, was a member of the New York Stock Exchange and was actively engaged in the business of buying and selling securities for his own account. He made a number of short sales in connection with which he borrowed shares of stock for delivery, and agreed to pay the lender the amount of all dividends paid on such shares until the borrowed shares were returned. In some cases, he also paid the lender a premium for the loan of the shares. In the year 1936 he paid commissions to other brokers on sales of stock. The…

2Cases cited9 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Helvering v. WinmillSupreme Court of the United States · 1938
  3. Wilmington Trust Co. v. HelveringSupreme Court of the United States · 1942
  4. Provost v. United StatesSupreme Court of the United States · 1926
  5. Spreckels v. CommissionerSupreme Court of the United States · 1942

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

3Cited by7 opinions

  1. Commissioner v. WieslerCourt of Appeals for the Sixth Circuit · 1947
  2. Commissioner of Internal Revenue v. WilsonCourt of Appeals for the Ninth Circuit · 1947
  3. Main Line Distributors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1963
  4. Hendricks v. CommissionerUnited States Tax Court · 1968
  5. 1955 Production Exposition, Inc. v. CommissionerUnited States Tax Court · 1963

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

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