Legal Opinion
Spear Box Co., Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 7, 1950No. 21555_1PublishedCited by 14 opinions
1Opinion of the Court
CHASE, Circuit Judge.
This case primarily involves the question whether, on the one hand, the petitioner realized income from, or, on the other, received a gift by virtue of, the retirement of its bonds at a cost to it of less than their face value. The facts are fully set forth in the opinion of the Tax Court, 13 T.C. 238, but a brief statement of the more pertinent ones may, perhaps, be helpful.
Petitioner, a New York corporation, was organized in 1939 pursuant to a plant of reorganization of petitioner’s predecessor, the G. & S. Holding Co., Inc.., which held all the capital stock of Spear…
2Cases cited2 opinions
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
3Cited by14 opinions
- Harold Wener v. Commissioner of Internal Revenue, Molly Wener v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- George W. Gibbs and Kathleen I. Gibbs v. Laurie W. Tomlinson, District Director of Internal Revenue for the District of FloridaCourt of Appeals for the Fifth Circuit · 1966
- America-Southeast Asia Co. v. CommissionerUnited States Tax Court · 1956
- Eleanor A. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Capitol Coal Corp. v. CommissionerUnited States Tax Court · 1956
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