Legal Opinion
Charles Town, Incorporated v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided January 31, 1967No. 10645_1PublishedCited by 22 opinions
1Opinion of the Court
CRAVEN, Circuit Judge:
The Tax Court sustained the action of the Commissioner of Internal Revenue in redistributing income for fiscal years ending November 30, 1958, and 1959, from Fairmount Steel Corporation to Charles Town, Incorporated, under Sections 61 and 482 of the Internal Revenue Code of 1954. 1 The Commissioner’s allocation under Section 482 is predicated on the alleged shifting of profits from one controlled entity (Charles Town) to another (Fairmount) for the purpose of utilizing net operating loss carryovers of the latter. Charles Town has petitioned this court under 26 U.S.C.A.…
2Cases cited14 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Lucas v. EarlSupreme Court of the United States · 1930
- Higgins v. SmithSupreme Court of the United States · 1940
- Helvering v. EubankSupreme Court of the United States · 1941
9 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Marc's Big Boy-Prospect, Inc. v. CommissionerUnited States Tax Court · 1969
- Likins-Foster Honolulu Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1969
- W. Braun Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1968
17 more not listed; retrieve them via the Exa API.