Legal Opinion
Great Cruz Bay, Inc., St. John, Virgin Islands v. Reuben B. Wheatley, Commissioner of Finance, Government of the Virgin Islands
Court of Appeals for the Third Circuit
Decided March 28, 1974No. 73-1452PublishedCited by 15 opinions
1Opinion of the Court
OPINION OF THE COURT
By MARIS, Circuit Judge
The question presented by this appeal is whether the taxpayer, Great Cruz Bay, Inc., a Virgin Islands corporation, is entitled to elect Virgin Islands income tax treatment as a small business corporation under subchapter S of the Internal Revenue Code, 26 U.S.C. §§ 1371 et seq. For the purposes of subchapter S, section 1371(a) of the Code defines a small business corporation to mean a domestic corporation which does not, inter alia, “(3) have a nonresident alien as a shareholder”. The answer turns on whether, under the income tax law as applied in…
2Cases cited8 opinions
- George S. Krasnov v. Brendan DinanCourt of Appeals for the Third Circuit · 1972
- Williamson v. OsentonSupreme Court of the United States · 1914
- George H. T. Dudley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Chicago Bridge and Iron Company, Ltd. v. Ruben B. Wheatley, Commissioner of FinanceCourt of Appeals for the Third Circuit · 1970
- Sayre & Company, Ltd. v. R. A. Riddell, Commissioner of Revenue and TaxationCourt of Appeals for the Ninth Circuit · 1968
3 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Anand Prakash v. American UniversityCourt of Appeals for the D.C. Circuit · 1984
- Condor Int'l v. CommissionerUnited States Tax Court · 1992
- Preece v. CommissionerUnited States Tax Court · 1990
- Vitco, Inc. v. Government of the Virgin Islands and Reuben Wheatley, Commissioner of FinanceCourt of Appeals for the Third Circuit · 1977
- Lee and Joan Holmes v. Director of Revenue and Taxation, Government of GuamCourt of Appeals for the Ninth Circuit · 1987
10 more not listed; retrieve them via the Exa API.