Legal Opinion
The St. Louis Company, a Delaware Corporation (In Dissolution) v. The United States of America
Court of Appeals for the Third Circuit
Decided September 24, 1956No. 11769_1PublishedCited by 15 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
Where a personal holding company’s deficit in “earnings or profits accumulated after February 28, 1913” exceeds its net income for the taxable year is a distribution out of such income, during the taxable year, in complete liquidation of the company, a “dividend” within the meaning of the dividends paid credit provisions of the Internal Revenue Code of 1939, as amended to 1948?
That is the single issue presented by this appeal from the judgment of the United States District Court for the District of Delaware in favor of the taxpayer.
The facts were stipulated arid may be…
2Cases cited22 opinions
- Crooks v. HarrelsonSupreme Court of the United States · 1930
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Hellmich v. HellmanSupreme Court of the United States · 1928
- United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
- Helvering v. Credit Alliance Corp.Supreme Court of the United States · 1942
17 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Associated Telephone and Telegraph Company, and Cross v. United States of America, and CrossCourt of Appeals for the Second Circuit · 1962
- Commissioner of Internal Revenue v. Mercantile National Bank at DallasCourt of Appeals for the Fifth Circuit · 1960
- Anderson v. CommissionerUnited States Tax Court · 1976
- Atlantic City Electric Company v. United StatesUnited States Court of Claims · 1958
- L. C. Bohart Plumbing & Heating Co. v. CommissionerUnited States Tax Court · 1975
10 more not listed; retrieve them via the Exa API.