Legal Opinion
Wells Fargo Bank & Union Trust Co., as of the Estate of Ivey L. Borden, Deceased v. United States
Court of Appeals for the Ninth Circuit
Decided September 6, 1955No. 14270PublishedCited by 5 opinions
1Opinion of the Court
McALLISTER, Circuit Judge.
Appellant, as executor of the estate of Ivey L. Borden, deceased, appeals from a judgment denying recovery for overpayment of federal excess profits taxes. The issue before us is whether a transaction in which a certain corporation, of which appellant’s decedent, Mr. Borden, was sole stockholder, acquired the properties of a predecessor corporation of which he was also sole stockholder, constituted a tax-free reorganization. The district court held that it was not a tax-free reorganization within the meaning of Section 112(i) of the Revenue Act of 1932, 26…
2Cases cited6 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Palm Springs Holding Corp. v. CommissionerSupreme Court of the United States · 1942
- Helvering v. New President CorporationCourt of Appeals for the Eighth Circuit · 1941
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3Cited by5 opinions
- New York Guardian Mortgagee Corp. v. ClelandDistrict Court, S.D. New York · 1979
- Western Massachusetts Theatres, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1956
- United States v. Improved Premises Located at Northwest Corner of Irving Place & Sixteenth StreetDistrict Court, S.D. New York · 1962
- Goldstein Brothers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
- Ralphs Grocery Co. & Subsidiaries v. Comm'rUnited States Tax Court · 2011