Legal Opinion

Litchfield Securities Corporation v. United States

Court of Appeals for the Second Circuit

Decided December 5, 1963No. 81, Docket 28290PublishedCited by 12 opinions

1Opinion of the Court

FRIENDLY, Circuit Judge.

This appeal is by a personal holding company from an order of Judge Dawson in the Southern District of New York, dismissing its complaint in a suit, for refund of a tax on undistributed personal holding company income. In determining the amount of such income,, upon which severe taxes are imposed, § 545(b) (5) of the Internal Revenue Code-of 1954 permits deduction of net long-term capital gains 1 after reduction of these by federal income taxes attributable to them. This suit requires interpretation of the statutory direction for calculating how much tax is…

2Cases cited4 opinions

  1. Commissioner v. AckerSupreme Court of the United States · 1959
  2. Delaware Realty & Investment Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
  3. Pitcairn Co. v. United StatesUnited States Court of Claims · 1960
  4. Bessemer Securities Corporation v. The United StatesUnited States Court of Claims · 1963

3Cited by12 opinions

  1. Berger v. HecklerCourt of Appeals for the Second Circuit · 1985
  2. Berger v. HecklerCourt of Appeals for the Second Circuit · 1985
  3. Kluger Associates, Inc. v. CommissionerUnited States Tax Court · 1978
  4. Ellis Corp. v. CommissionerUnited States Tax Court · 1972
  5. Kluger Associates, Inc. v. CommissionerCourt of Appeals for the Second Circuit · 1980

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