Legal Opinion
Gibson v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided February 10, 1943No. 3PublishedCited by 14 opinions
1Opinion of the Court
AUGUSTUS N. HAND, Circuit Judge.
The facts were stipulated and may be summarized as follows:
On June 15, 1936, the taxpayer was the owner of 24,510 shares of the common capital stock of Manufacturers Trust Company (herein referred to as Manufacturers). Manufacturers had only this one class of stock outstanding. On June 10, 1936, Manufacturers was duly authorized, pursuant to the laws of the State of New York, to increase its capital by issuing 500,000 shares of convertible preferred stock, par value $20. The owners of the new convertible preferred were to have the right to convert it into…
2Cases cited4 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- Choate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
3Cited by14 opinions
- Commissioner v. GordonSupreme Court of the United States · 1968
- Gerald R. Redding and Dorothy M. Redding and Thomas W. Moses and Anne M. Moses v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
- Commissioner of Internal Revenue v. Irving Gordon and Margaret Gordon, Irving Gordon and Margaret Gordon v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Ring v. Authors' League of America, Inc.Court of Appeals for the Second Circuit · 1951
- Lloyd v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1946
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