Legal Opinion
Helvering v. Scottish American Inv. Co.
Court of Appeals for the Fourth Circuit
Decided November 8, 1943No. Nos. 5122-5124PublishedCited by 4 opinions
1Opinion of the Court
DOBIE, Circuit Judge.
Scottish American Investment Company, Limited, British Assets Trust, Limited, and Second British Assets Trust, Limited, are all corporations organized under the laws of Great Britain. Each has its principal office in Edinburgh, Scotland. For convenience, the three corporations are hereinafter called the Trusts. The Trusts were engaged in the business of investing the funds of their security-holders. These investments were made primarily for the purposes of security of principal and adequacy of income.
On December 2, 1936, the Trusts had over $40,000,000 invested in…
2Cases cited3 opinions
- Edwards v. Chile Copper Co.Supreme Court of the United States · 1926
- BW Jones Trust v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1943
- Linen Thread Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
3Cited by4 opinions
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
- Simenon v. CommissionerUnited States Tax Court · 1965
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1944
- Simenon v. CommissionerUnited States Tax Court · 1965