Legal Opinion

Marwais Steel Company v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided December 20, 1965No. 19068PublishedCited by 17 opinions

1Opinion of the Court

CHAMBERS, Circuit Judge:

Wilmington Metal Manufacturing Company, wholly owned by Marwais Steel Company, lived at the whim of the latter.

Marwais organized Wilmington in 1951 to do a special wheel manufacturing job. The latter company was dissolved at the will of Marwais in August, 1956. Wilmington was never successful in business and existed on loans from Marwais which amounted to $57,857.35 on the eve of dissolution. Just before dissolution of Wilmington, Marwais, by a board of directors resolution, forgave the whole amount. At dissolution, Wilmington surrendered its cash assets of $110.02 to…

2Cases cited4 opinions

  1. Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
  2. McLaughlin v. Pacific Lumber Co.Supreme Court of the United States · 1934
  3. Marwais Steel Co. v. CommissionerUnited States Tax Court · 1962
  4. Spokane Dry Goods Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942

3Cited by17 opinions

  1. Miller v. CommissionerUnited States Tax Court · 1967
  2. Covil Insulation Co. v. CommissionerUnited States Tax Court · 1975
  3. Textron, Inc. v. United StatesCourt of Appeals for the First Circuit · 1977
  4. Estate of Joslyn v. CommissionerUnited States Tax Court · 1972
  5. Duquesne Light Holdings Inc v. Commissioner of Internal RevenCourt of Appeals for the Third Circuit · 2017

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