Legal Opinion

Argo v. Commissioner

United States Tax Court

Decided July 20, 1944No. Docket Nos. 109996, 112248Published

1. The judgment of a Federal District Court in an action between petitioner and a collector of internal revenue for recovery of income tax paid by petitioner for 1937 involved the same question as is here involved for 1938 and 1939, but the parties to the two proceedings were not identical.

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1. The judgment of a Federal District Court in an action between petitioner and a collector of internal revenue for recovery of income tax paid by petitioner for 1937 involved the same question as is here involved for 1938 and 1939, but the parties to the two proceedings were not identical. Held, that the judgment of the Federal District Court does not preclude this Court from further considering that question as to 1938 and 1939. 2. The judgment of a Federal District Court in an action between petitioner and a collector of internal revenue for recovery of income tax paid by petitioner for…

1Opinion of the Court

M. M. Argo, Petitioner, v. Commissioner of Internal Revenue, Respondent

Argo v. Commissioner

Docket Nos. 109996, 112248

United States Tax Court

3 T.C. 1120; 1944 U.S. Tax Ct. LEXIS 83;

July 20, 1944, Promulgated

Decision will be entered under Rule 50.

1. The judgment of a Federal District Court in an action between petitioner and a collector of internal revenue for recovery of income tax paid by petitioner for 1937 involved the same question as is here involved for 1938 and 1939, but the parties to the two proceedings were not identical. Held, that the judgment of the Federal District Court does not…

2Cases cited18 opinions

  1. Cromwell v. County of SacSupreme Court of the United States · 1877
  2. Lucas v. EarlSupreme Court of the United States · 1930
  3. Southern Pacific Railroad v. United StatesSupreme Court of the United States · 1897
  4. Sunshine Anthracite Coal Co. v. AdkinsSupreme Court of the United States · 1940
  5. Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933

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