Legal Opinion
Ertegun v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided March 9, 1976No. Nos. 553, 756, 757, Dockets 75-4193, 75-4194, 75-4195PublishedCited by 1 opinion
1Opinion of the Court
J. JOSEPH SMITH, Circuit Judge:
Until December 1, 1967, Atlantic Records Sales Company, Inc. was a closely-held corporation, qualifying for and electing to receive the special tax treatment of Subchapter S of the Internal Revenue Code. 26 U.S.C. § 1371 et seq. The appellants are the former shareholders of Atlantic who, pursuant to the provisions of Subchapter S, included Atlantic’s undistributed taxable income in their own gross (and therefore taxable) incomes on a pro rata basis. 26 U.S.C. § 1373.
This appeal arises from a disagreement between the appellant-shareholders and the Internal…
2Cases cited5 opinions
- Brown v. HelveringSupreme Court of the United States · 1934
- Central Cuba Sugar Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Central Cuba Sugar CoCourt of Appeals for the Second Circuit · 1952
- Pittsburgh Milk Co. v. CommissionerUnited States Tax Court · 1956
- Scott Krauss News Agency, Inc. v. CommissionerUnited States Tax Court · 1964
- J. J. Little & Ives Co. v. CommissionerUnited States Tax Court · 1966