Legal Opinion
The Smoot Sand & Gravel Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided January 11, 1960No. 7886PublishedCited by 99 opinions
1Opinion of the Court
SOBELOFF, Chief Judge.
This case, here for the second time, concerns the taxpayer’s liability for the years 1945-1950 for surtaxes under § 102 of the Internal Revenue Code of 1939, 26 U.S.C.A. § 102 1 by reason of the alleged accumulation of profits “for the purpose of preventing the imposition of the surtax” upon its sole shareholder, Columbia Sand & Gravel Company, Inc., and upon L. E. Smoot, owner of all the common stock of Columbia. The Tax Court having sustained the Commissioner’s position in the first trial of the case, this court, on review, concluded its opinion as follows:
“Accordingly,…
2Cases cited4 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
- Pelton Steel Casting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
- Jerone E. Casey, Transferee of the Bankers Development Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1959
3Cited by99 opinions
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
- Ivan Allen Co. v. United StatesSupreme Court of the United States · 1975
- John P. Scripps Newspapers v. CommissionerUnited States Tax Court · 1965
- Bremerton Sun Publishing Co. v. CommissionerUnited States Tax Court · 1965
- American Metal Products Corporation v. Commissioner of Internal Revenue, Adler Metal Products Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
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