Legal Opinion

J. C. Cornillie Co. v. United States

District Court, E.D. Michigan

Decided November 7, 1968No. Civ. A. No. 25676PublishedCited by 1 opinion

1Opinion of the Court

OPINION

TALBOT SMITH, District Judge.

This action is a suit for refund by plaintiff, J. C. Cornillie Company, against the United States of America, to recover income tax in the amount of $15,-600.00 plus statutory interest which was assessed against it for the fiscal years ending March 31, 1960 and 1961. (Stip. 1f 2) It is a case requiring much analysis in detail since the problem is one of differentiating form from substance. It stems, as we later point out, from a change in the economics of, and practices involved in, the heating of homes.

The Court has jurisdiction and venue in this action…

2Cases cited10 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. United States v. AndersonSupreme Court of the United States · 1926
  3. Reinecke v. SpaldingSupreme Court of the United States · 1930
  4. Nannie v. Compton v. United States of AmericaCourt of Appeals for the Fourth Circuit · 1964
  5. Anchor Cleaning Service, Inc. v. CommissionerUnited States Tax Court · 1954

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3Cited by1 opinion

  1. Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973

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