Legal Opinion
Fowler Hosiery Company, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided April 13, 1962No. 13506_1PublishedCited by 20 opinions
1Opinion of the Court
SWYGERT, Circuit Judge.
Petitioner, Fowler Hosiery Company, Inc., appeals from a decision of the Tax-Court, 36 T.C. 201, No. 20, affirming a deficiency in the amount of $205,850.70 in Fowler’s income tax for the year of 1955. The Tax Court sustained the Commissioner of Internal Revenue’s determination that a $1,500,000 cash distribution (which Fowler received from its wholly owned Canadian subsidiary, Fowler Hosiery Company of Canada, Limited) was a distribution in partial liquidation within the meaning of Section 346(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 346(a); and that the…
2Cases cited5 opinions
- Hellmich v. HellmanSupreme Court of the United States · 1928
- Fowler Hosiery Co. v. CommissionerUnited States Tax Court · 1961
- Tri-Lakes SS Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1945
- Associated Telephone and Telegraph Co. v. United StatesDistrict Court, S.D. New York · 1961
- Freeport Sulphur Company v. United StatesUnited States Court of Claims · 1958
3Cited by20 opinions
- Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Gallagher v. CommissionerUnited States Tax Court · 1962
- Berry Petroleum Co. v. CommissionerUnited States Tax Court · 1995
- Associated Telephone and Telegraph Company, and Cross v. United States of America, and CrossCourt of Appeals for the Second Circuit · 1962
- Baan v. CommissionerUnited States Tax Court · 1969
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