Legal Opinion
Royer's, Inc. v. United States
District Court, W.D. Pennsylvania
Decided June 24, 1958No. Civ. A. No. 15758PublishedCited by 3 opinions
1Opinion of the Court
GOURLEY, Chief Judge.
This is a corporate income tax proceeding which arises out of the termination of a profit sharing trust in which the taxpayer claims a right to recover from the United States of America overpayment of corporate income tax for the fiscal year of 1950, or in the alternative for the fiscal year 1949.
The question for determination is—
Where a taxpayer made contributions to a profit sharing trust under a profit sharing plan for the benefit of the employees in the years 1946, 1947 and 1948 in excess of the amount which it Was permitted to deduct under Section 23(p) (1) (C),…
2Cases cited8 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. GrimaudSupreme Court of the United States · 1911
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- United States v. BirdsallSupreme Court of the United States · 1914
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3Cited by3 opinions
- Licorería Trigo, Inc. v. Secretario de HaciendaSupreme Court of Puerto Rico · 1967
- Royer's, Inc. v. United StatesCourt of Appeals for the Third Circuit · 1959
- Licorería Trigo, Inc. v. Secretary of the TreasurySupreme Court of Puerto Rico · 1967