International Bedaux Co., Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
1Opinion of the Court
CLARK, Circuit Judge.
Presented by this petition for review is a narrow issue arising out of interesting and peculiar circumstances not likely to be often, if ever, repeated. The question is whether petitioner, a personal holding company, succeeded in making distribution of its income in 1942 so as to avoid the heavy surtax assessed under I.R.C. § 500, 26 U.S.C. § 500. Petitioner was then owned by Mr. and Mrs. Charles E. Bedaux, the husband owning 10 per cent, the wife 90 per cent, of its capital stock. Mr. and Mrs. Bedaux were in Occupied France in 1942 and prior thereto, and were unable to…
2Cases cited9 opinions
- Cornell Steamboat Company v. John J. Coughlin and J. C. Davis, Director General of Railroads, EtcSupreme Court of the United States · 1927
- Regensburg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
- Chattanooga Sav. Bank v. BrewerCourt of Appeals for the Sixth Circuit · 1927
- Brooks v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1929
- Fitch v. HelveringCourt of Appeals for the Eighth Circuit · 1934
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3Cited by2 opinions
- Olaf C. Akland, and Bertha A. Akland v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Sachs v. Commissioner of Internal Revenue. Slaymaker Lock Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953