Legal Opinion
Frederick Smith Enter. Co. v. Commissioner of Int. Rev.
Court of Appeals for the Sixth Circuit
Decided April 12, 1948No. 10578PublishedCited by 13 opinions
1Opinion of the Court
SIMONS, Circuit Judge.
The basic question on this appeal is whether the petitioner was a personal holding company in the years 1937, 1939 and 1940, and this depends upon whether certain of its gains are to be classified as rents so as to preclude its classification as a personal holding company. This in turn depends,upon whether specific amendments to the Internal Revenue Code, made in 1937, are to be given a literal reading or are to be construed in the light of the Congressional purpose in enacting them.
By Title 26 U.S.C.A.Int.Rev.Code, § 501, a personal holding company is defined as any…
2Cases cited14 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Chicago & Southern Air Lines, Inc. v. Waterman Steamship Corp.Supreme Court of the United States · 1948
- Cabell v. MarkhamCourt of Appeals for the Second Circuit · 1945
- United States v. DickersonSupreme Court of the United States · 1940
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
9 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Matthews v. CommissionerUnited States Tax Court · 1989
- Bachmura v. CommissionerUnited States Tax Court · 1959
- Warfield v. CommissionerUnited States Tax Court · 1985
- Graves v. CommissionerUnited States Tax Court · 1987
- Branham v. United StatesDistrict Court, W.D. Kentucky · 1955
8 more not listed; retrieve them via the Exa API.