Friedlander Corp. v. Commissioner
United States Tax Court
1. Held, that from July 1, 1943, to March 31, 1946, the petitioner and Louis Friedlander & Sons, a partnership, were owned or controlled directly or indirectly by the same interests. 2. Amounts of petitioner's general and administrative expenses incurred in 1943, 1944, and 1945 allocable to the partnership determined.
1Opinion of the Court
Withey, Judge:
This proceeding is before us under mandate from the United States Court of Appeals for the Fifth Circuit to redetermine deficiencies in accordance with the opinion of that court which appears at 216 F. 2d 757. As shown in our report at 19 T. C. 1197, filed in this proceeding when it formerly was before us, one of the issues presented was whether the income of the petitioner for 1943, 1944, and 1945 should include the income of Louis Friedlander & Sons, which the petitioner contended was a partnership and recognizable as such for tax purposes or, in the alternative, whether…
2Cases cited3 opinions
- Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- The Friedlander Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954
- John L. Denning & Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
3Cited by10 opinions
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Frank v. International Canadian Corp.Court of Appeals for the Ninth Circuit · 1962
- Frank v. International Canadian CorporationCourt of Appeals for the Ninth Circuit · 1962
- Brittingham v. CommissionerCourt of Appeals for the Fifth Circuit · 1979
- Gettler v. CommissionerUnited States Tax Court · 1975
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