Legal Opinion
Commissioner of Internal Revenue v. First Nat. Bank
Court of Appeals for the Third Circuit
Decided June 17, 1939No. 6622, 6614-6621PublishedCited by 12 opinions
1Opinion of the Court
DAVIS, Circuit Judge.
The basic issue, upon which depends to a large extent the decision in all of the cases here involved, is whether or not the Independent Oil Company (hereinafter called the old company), respondent in Appeal No. 6614, realized a taxable gain as a result of certain transactions which took place in the year 1930.
In that year, in accordance with the terms of a contract previously entered into, the old company transferred approximately 86% of its assets to a newly formed corporation, the Independent Oil Company, Inc. (hereinafter called the new company), in exchange for all of…
2Cases cited4 opinions
- Groman v. CommissionerSupreme Court of the United States · 1937
- Helvering v. BashfordSupreme Court of the United States · 1938
- Smith v. CommissionerUnited States Board of Tax Appeals · 1936
- Independent Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1936
3Cited by12 opinions
- James Armour, Inc. v. CommissionerUnited States Tax Court · 1964
- Moffatt v. CommissionerUnited States Tax Court · 1964
- United Light & Power Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1939
- J. M. Turner and Company, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
- John G. Moffatt v. Commissioner of Internal Revenue, Mary E. Moffatt v. Commissioner of Internal Revenue, John G. Moffatt and Mary E. Moffatt v. Commissioner of Internal Revenue, Frank E. Nichol v. Commissioner of Internal Revenue, Ruth H. Nichol v. Commissioner of Internal Revenue, Frank E. Nichol and Ruth H. Nichol v. Commissioner of Internal Revenue, George C. Murray and Anna Mae Murray v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1966
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