Legal Opinion
Roebling v. Commissioner
Court of Appeals for the Third Circuit
Decided July 1, 1944No. 8519PublishedCited by 23 opinions
1Opinion of the Court
KALODNER, District Judge.
This appeal presents three questions: (1) Whether the transaction hereafter stated between a lessor corporation and a. lessee corporation constitued a “statutory merger”, within the meaning of Sec. 112(g) (1) (A) of the Revenue Act of 1938, 26 U.S.C.A. Int.Rev.Code, § 112(g) (1) (A);1 (2) whether the doctrine of “continuity of interest” as enunciated in LeTulle v. Scofield, 308 U.S. 415, 60 S.Ct. 313, 84 L.Ed. 355, applies to a "statutory merger”, and (3) whether under the facts a “continuity of interest” actually existed.
Taxability on gain resulting to the petitioner…
2Cases cited10 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
5 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Southwest Natural Gas Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Estate of Howes v. CommissionerUnited States Tax Court · 1958
- Arden S. Heverly and Sophia S. Heverly v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1980
- Heintz v. CommissionerUnited States Tax Court · 1955
- West Side Federal Savings and Loan Association of Fairview Park v. United StatesCourt of Appeals for the Sixth Circuit · 1974
18 more not listed; retrieve them via the Exa API.