Legal Opinion

Securities Co. v. Commissioner

Court of Appeals for the Second Circuit

Decided April 10, 1933No. Nos. 290, 291PublishedCited by 5 opinions

1Opinion of the Court

AUGUSTUS N. HAND, Circuit Judge.

The government’s claim to additional income taxes found to be due, is based on a sale by the Securities Company in 1924 of 3,000 shares of stock of the Missouri Pacific Railroad Company. Clinchfield Securities Company is assessed a part of the additional tax because, being a wholly owned subsidiary of tbe Securities Company, the two companies filed a consolidated return for 1924. If any additional tax is due, there is no objection to the division of the tax between the companies.

The stock of the Missouri Pacific Railroad Company that was sold by the taxpayer in…

2Cases cited2 opinions

  1. Cortland Specialty Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1932
  2. De Blois v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1929

3Cited by5 opinions

  1. Ahles Realty Corp. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1934
  2. Seiberling Rubber Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1948
  3. Forstmann v. RogersCourt of Appeals for the Third Circuit · 1942
  4. United States v. Galveston-Houston Electric Co.Court of Appeals for the First Circuit · 1936
  5. Seiberling Rubber Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1948

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