Legal Opinion
Schner-Block Company, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided April 2, 1964No. 252, Docket 28527PublishedCited by 12 opinions
1Opinion of the Court
MARSHALL, Circuit Judge:
The issue on this petition is whether the taxpayer, a typical family corporation, is entitled to a deduction of $2,400 on its income tax return for the fiscal year ending Ocober 31, 1959 for payments to Florence Schner, widow of the founder of the corporation and holder of 200 shares of its preferred stock. Petitioner claims that this deduction was proper under sections 404(a) (5) and 162 of the Internal Revenue Code of 1954; respondent relies on the Tax Court’s ultimate finding that the payments were non-deductible, either as a gift or a dividend to the widow.
The…
2Cases cited14 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Ruth T. Lengsfield, Coralie Mayer Lengsfield and Blanche L. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Commissioner of Internal Revenue v. Fifth Avenue Coach Lines, Inc., Fifth Avenue Coach Lines, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Fifth Ave. Coach Lines,Inc. v. CommissionerUnited States Tax Court · 1959
- Barbourville Brick Co. v. CommissionerUnited States Tax Court · 1961
9 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- John C. Nordt Co. v. CommissionerUnited States Tax Court · 1966
- Rubber Associates, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
- Montgomery Engineering Company v. United StatesDistrict Court, D. New Jersey · 1964
- Bank of Palm Beach & Trust Co. v. United StatesUnited States Court of Claims · 1973
- Willmark Service System, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
7 more not listed; retrieve them via the Exa API.