Legal Opinion

Seeley v. Helvering

Court of Appeals for the Second Circuit

Decided May 6, 1935No. 208PublishedCited by 17 opinions

1Opinion of the Court

L. HAND, Circuit Judge.

This appeal raises the question of a taxpayer’s power to have his income tax for the year 1929 computed by the use of inventories under section 22 (c) of the Revenue Act of 1928 (26 USCA § 2022 (c). He was a stockbroker in New York City, associated with, but not a member of, a firm, some of whose orders he executed on the floor of the exchange; but he also did business upon his own account, buying and selling for himself on margin. He was, as we understand it, what is commonly known as a “floor trader,” and he had no personal customers. In making his return he claimed…

2Cases cited5 opinions

  1. Bonwit Teller & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1931
  2. Sweets Co. of America, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Finance & Guaranty Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1931
  4. John M. Parker Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1931
  5. Harriman National Bank v. Com'r of Internal RevenueCourt of Appeals for the Second Circuit · 1930

3Cited by17 opinions

  1. Schafer v. HelveringCourt of Appeals for the D.C. Circuit · 1936
  2. Stephen Marrin and Jane Marrin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
  3. Commissioner of Internal Revenue v. BurnettCourt of Appeals for the Fifth Circuit · 1941
  4. Commissioner of Internal Revenue v. StevensCourt of Appeals for the Second Circuit · 1935
  5. George E. Warren Co. v. United StatesDistrict Court, D. Massachusetts · 1944

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