Legal Opinion
Commissioner of Internal Revenue v. Segall
Court of Appeals for the Sixth Circuit
Decided September 16, 1940No. 8197, 8198PublishedCited by 63 opinions
1Opinion of the Court
ARANT, Circuit Judge.
The Commissioner of Internal Revenue asserted deficiencies in respondents’ taxes for the year 1932, on the theory that certain transactions that eventuated in the dissolution of the Silent Automatic Company constituted a sale of its assets to the Tim-ken-Detroit Company, and that respondents are liable as transferees for taxes upon that part of the profit distributed to them as stockholders. The Board of Tax Appeals held, in accordance with respondents’ contentions, that the transactions constituted a tax-free reorganization, and the Commissioner now petitions for review…
2Cases cited20 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
- Lucas v. North Texas Lumber Co.Supreme Court of the United States · 1930
- Cortland Specialty Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1932
15 more not listed; retrieve them via the Exa API.
3Cited by63 opinions
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Baird v. CommissionerUnited States Tax Court · 1977
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Hallmark Cards, Inc. v. CommissionerUnited States Tax Court · 1988
- Deyoe v. CommissionerUnited States Tax Court · 1976
58 more not listed; retrieve them via the Exa API.