Legal Opinion
Tennessee Life Insurance Company v. R. L. Phinney, District Director of Internal Revenue at Austin, Texas
Court of Appeals for the Fifth Circuit
Decided July 15, 1960No. 18160_1PublishedCited by 11 opinions
1Opinion of the Court
TUTTLE, Circuit Judge.
This appeal tests the correctness of the Internal Revenue Commissioner’s denial of a deduction of real estate taxes to one of two wholly owned subsidiaries under the provisions of Section 45 of the Internal Revenue Code of 1939 as Amended, 26 U.S.C.A., Internal Revenue Code of 1939, § 45, when the owner corporation, on January 1st, the date the lien for taxes attached, conveyed the property under a liquidation on January 19th to the second wholly owned subsidiary corporation.
The facts are not in dispute. On January 1, 1953, Tennessee Gas Transmission Corporation (T.G.T.)…
2Cases cited7 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Magruder v. SuppleeSupreme Court of the United States · 1942
- Jud Plumbing & Heating, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Simon J. Murphy Company and Social Research Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Dillard-Waltermire, Inc. v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
2 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- South Texas Rice Warehouse Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Francis L. Rooney and Irene Rooney v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Broida, Stone & Thomas, Inc. v. United StatesDistrict Court, N.D. West Virginia · 1962
- Woodward Iron Company v. United StatesCourt of Appeals for the Fifth Circuit · 1968
- Doric Co. v. CommissionerUnited States Tax Court · 1963
6 more not listed; retrieve them via the Exa API.