Legal Opinion
Zenz v. Quinlivan
Court of Appeals for the Sixth Circuit
Decided June 11, 1954No. 12066PublishedCited by 74 opinions
1Opinion of the Court
GOURLEY, District Judge.
The appeal relates to the interpretation of Section 115(g) of the Internal Revenue Code and poses the question—
Is a distribution of substantially all of the accumulated earnings and surplus of a corporation, which are not necessary to the conduct of the business of the corporation, in redemption of all outstanding shares of stock of said corporation owned by one person essentially equivalent to the distribution of a taxable dividend under the Internal Revenue Code?
The District Court answered in the affirmative and sustained a deficiency assessment by the Commissioner…
2Cases cited8 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. TowerSupreme Court of the United States · 1946
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Hellmich v. HellmanSupreme Court of the United States · 1928
- United States v. Cummins Distilleries CorporationCourt of Appeals for the Sixth Circuit · 1948
3 more not listed; retrieve them via the Exa API.
3Cited by74 opinions
- Television Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Anna I. Woodworth v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
- Edgar S. Idol, Katherine G. Idol, and Speedway Transports, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Television Industries, Inc. v. CommissionerUnited States Tax Court · 1959
- Kobacker v. CommissionerUnited States Tax Court · 1962
69 more not listed; retrieve them via the Exa API.