Legal Opinion
Commissioner of Internal Revenue v. Walter L. And Helen Morgan
Court of Appeals for the Third Circuit
Decided April 13, 1961No. 13306PublishedCited by 43 opinions
1Opinion of the Court
STALEY, Circuit Judge.
This petition for review requires us to determine whether distributions made to *677a shareholder pursuant to a corporate liquidation are taxable as dividend income under subsection 112(c) (2) or as a long term capital gain under subsection 115(c) of the Internal Revenue Code of 1939, 26 U.S.C.A. (Int.Rev.Code 1939), which provisions control here.
For many years Wellington Fund, Inc. (“Fund”), a mutual fund, had separate contracts with Wellington Corporation (“transferor”) for investment advisory services, and with W. L. Morgan & Company (“transferee”) for the national…
2Cases cited5 opinions
- Lewis v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1949
- William Liddon v. Commissioner of Internal Revenue, Maria Prothro Liddon v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Trianon Hotel Co. v. CommissionerUnited States Tax Court · 1958
- Becher v. CommissionerCourt of Appeals for the Second Circuit · 1955
- Golden Nugget, Inc. v. CommissionerUnited States Tax Court · 1984
3Cited by43 opinions
- J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966
- South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
- James Armour, Inc. v. CommissionerUnited States Tax Court · 1964
- Wilson v. CommissionerUnited States Tax Court · 1966
- Moffatt v. CommissionerUnited States Tax Court · 1964
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