Legal Opinion
Putnam v. United States
Court of Appeals for the First Circuit
Decided May 25, 1945No. 4023PublishedCited by 14 opinions
1Opinion of the Court
MAHONEY, Circuit Judge.
This was an action to recover income taxes. The question presented is whether all the dividends received by the taxpayer in 1935 from Package Machinery Company were paid out of earnings or profits so as to be taxable under § 115(a) and (b) of the Revenue Act of 1934, 1 or whether a part of the amount received is not taxable because it represents a return of capital rather than the distribution of earnings or profits. The solution of this question in turn depends on whether the transaction in which Package Machinery Company acquired all the assets of another company in…
2Cases cited20 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Commissioner of Internal Revenue v. SansomeCourt of Appeals for the Second Circuit · 1932
- Commissioner of Internal Revenue v. SA Woods MacH. Co.Court of Appeals for the First Circuit · 1932
- COMMISSION OF INT. REV. v. Air Reduction Co.Court of Appeals for the Second Circuit · 1942
15 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Commissioner v. MunterSupreme Court of the United States · 1947
- Commissioner v. PhippsSupreme Court of the United States · 1949
- Bazley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1946
- Frelbro Corp. v. CommissionerUnited States Tax Court · 1961
- Bateman v. CommissionerUnited States Tax Court · 1963
9 more not listed; retrieve them via the Exa API.