Legal Opinion

Commissioner v. Thompson

Court of Appeals for the Third Circuit

Decided May 27, 1955No. Nos. 11370, 11371, 11373, 11374PublishedCited by 9 opinions

1Opinion of the Court

KALODNER, Circuit Judge.

The taxpayers and the Commissioner have appealed from the decisions of the Tax Court fixing the value of certain contracts at $250,000. 21 T.C. 448. The taxpayers contend that on the evidence the value could only have been fixed somewhere between $750,000 and $854,000. The Commissioner contends that the value must be deemed to be zero because the evidence affords no basis for valuation, but contrarily, if it does, then the Tax Court’s determination is correct.

The background of these appeals is set forth in our prior decision herein: 1953, 205 F.2d 73. The contracts…

2Cases cited13 opinions

  1. United States v. United States Gypsum Co.Supreme Court of the United States · 1948
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Hormel v. HelveringSupreme Court of the United States · 1941
  4. Helvering v. TaylorSupreme Court of the United States · 1935
  5. United States v. Yellow Cab Co.Supreme Court of the United States · 1949

8 more not listed; retrieve them via the Exa API.

3Cited by9 opinions

  1. Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  2. Milford R. Baumgardner and Pearl E. Baumgardner v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
  3. McGuire v. CommissionerUnited States Tax Court · 1965
  4. Webster Investors, Inc. (Successor by Merger to Webster Investment Company, Inc) v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
  5. George Fischer v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1961

4 more not listed; retrieve them via the Exa API.

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