Philadelphia & Reading Relief Asso. v. Commissioner
United States Board of Tax Appeals
1. A voluntary unincorporated association, composed of employees of a railroad company, or its successors, and of its or their affiliated, controlled, and leased lines, organized for the purpose of establishing and managing a relief fund for the payment of benefits to its members, in case of sickness, accident, or death, whose business is conducted by executive officers under the supervision of an advisory committee, a majority of which is elected by the members of the…
Read the full summary
1. A voluntary unincorporated association, composed of employees of a railroad company, or its successors, and of its or their affiliated, controlled, and leased lines, organized for the purpose of establishing and managing a relief fund for the payment of benefits to its members, in case of sickness, accident, or death, whose business is conducted by executive officers under the supervision of an advisory committee, a majority of which is elected by the members of the association, and otherwise doing business under the general form and mode of procedure of a corporation, is an "association,"…
1Opinion of the Court
*722OPINION.
ARundell:
At the outset we are confronted with the contention that petitioner is not an association, within the meaning of that term as used in section 1 of the Eevenue Act of 1918, and, therefore, is not subject to the income and profits taxes imposed upon corporations. The part of the statute pertinent to this proposition reads as follows:
Section 1. That when used in this Act—
The term “corporation” includes associations, joint-stock companies, and insurance companies; * * *
The word “ association ” appears to be used in the Act in its ordinary meaning. “In the United States this term…
2Cases cited21 opinions
- United Mine Workers v. Coronado Coal Co.Supreme Court of the United States · 1922
- Ould v. Washington Hospital for FoundlingsSupreme Court of the United States · 1877
- Coe v. Washington MillsMassachusetts Supreme Judicial Court · 1889
- Johnson v. Philadelphia & Reading R. R.Supreme Court of Pennsylvania · 1894
- Berry v. Knights Templars' & Masons' Life Indemnity Co.U.S. Circuit Court for the District of Western Missouri · 1891
16 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Hassett v. Associated Hospital Service CorporationCourt of Appeals for the First Circuit · 1942
- Polish Army Veterans Post 147 v. Commissioner of Internal Revenue, Polish Army Veterans Post 147 Home Association v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
- Smith v. ReynoldsDistrict Court, D. Minnesota · 1942
- Grange Ins. Asso. v. CommissionerUnited States Tax Court · 1961
7 more not listed; retrieve them via the Exa API.