Salvage v. Commissioner
Court of Appeals for the Second Circuit
1Opinion of the Court
SWAN, Circuit Judge.
The Board decreed a deficiency of $12,-005.38 in the petitioner’s income tax for the year 1929. He contends that not only is there no deficiency, but that he is entitled to a refund of $63,750. The controversy arises out of the fact that in 1929 the petitioner received $671,000 upon the redemption .of 6,100 shares of preferred stock of American Viscose Corporation. The question in dispute is what part of this sum represents capital net gain; and this involves a determination of the cost base properly attributable to the redeemed shares.
In December, 1922, the Viscose…
2Cases cited13 opinions
- Wilson v. BowersCourt of Appeals for the Second Circuit · 1932
- Commissioner of Internal Revenue v. Van VorstCourt of Appeals for the Ninth Circuit · 1932
- Helvering v. Brooklyn City R. Co.Court of Appeals for the Second Circuit · 1934
- United States v. S. F. Scott & Sons, Inc.Court of Appeals for the First Circuit · 1934
- Cox v. HelveringDistrict Court, District of Columbia · 1934
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3Cited by45 opinions
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Schmidlapp v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1938
- Majestic Securities Corp. v. Commissioner of Int. Rev.Court of Appeals for the Eighth Circuit · 1941
- BEALS'ESTATE v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1936
- Schaefer v. CommissionerUnited States Tax Court · 1995
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