Legal Opinion
Seas Shipping Company, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided January 16, 1967No. 30392_1PublishedCited by 29 opinions
1Opinion of the Court
*529ANDERSON, Circuit Judge:
On March 1, 1957, the taxpayer, Seas Shipping Company, Inc., sold ten ships to Moore-McCormack Lines, Inc. [hereafter Mooremac] for $5,466,668 in cash and notes and 300,000 shares of Moore-mac stock. In computing the amount realized from the sale, the taxpayer assigned a fair market value of $19.90 per share to the Mooremac stock. Mooremac resold two of the ships during 1957; and in computing its cost basis relative to the capital gains on the sales of the ships, Mooremac placed a value of $30 per share on the stock. The Commissioner determined deficiencies in the 1957…
2Cases cited9 opinions
- United States v. DavisSupreme Court of the United States · 1962
- Philadelphia Park Amusement Co. v. United StatesUnited States Court of Claims · 1954
- P. Dougherty Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1946
- United States v. General Shoe CorporationCourt of Appeals for the Sixth Circuit · 1960
- Moore-McCormack Lines, Inc. v. CommissionerUnited States Tax Court · 1965
4 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Briarcliff Candy Corporation, (Formerly Loft Candy Corporation) v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973
- Southern Natural Gas Company v. The United StatesUnited States Court of Claims · 1969
- Bar L Ranch, Inc., and in Intervention-Appellant v. Robert L. Phinney, United States of America, in Intervention-AppelleeCourt of Appeals for the Fifth Circuit · 1970
- Amerada Hess Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1975
24 more not listed; retrieve them via the Exa API.