Legal Opinion

Commissioner of Internal Revenue v. Mellon. Commissioner of Internal Revenue v. Scaife

Court of Appeals for the Third Circuit

Decided August 25, 1950No. 10092, 10093PublishedCited by 27 opinions

1Opinion of the Court

KALODNER, Circuit Judge.

Richard K. Mellon and his sister, Sarah Mellon Scaife, taxpayers, sold shares of stock of Pullman Incorporated (“Pullman”) in 1941 and 1942, and in 1941, 1942 and 1943, respectively. What the basis for this stock should be, for tax purposes, is the ultimate question in these cases. The taxpayers have claimed substantial losses, and the Tax Court, by unanimous decision, agreed. 12 T.C. 90.

The taxpayers received part of the Pullman stock in exchange for stock they directly held in the Standard Steel Car Company (“Standard”) in 1930. Part of the Pullman stock was received…

2Cases cited34 opinions

  1. Hormel v. HelveringSupreme Court of the United States · 1941
  2. Helvering v. SalvageSupreme Court of the United States · 1936
  3. Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
  4. Hazeltine Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1937
  5. Joyce v. GentschCourt of Appeals for the Sixth Circuit · 1944

29 more not listed; retrieve them via the Exa API.

3Cited by27 opinions

  1. United States v. Frank CostelloCourt of Appeals for the Second Circuit · 1955
  2. Commissioner of Internal Revenue v. DwyerCourt of Appeals for the Second Circuit · 1953
  3. The Crosley Corporation v. United StatesCourt of Appeals for the Sixth Circuit · 1956
  4. Wilson v. CommissionerUnited States Tax Court · 1966
  5. American Mfg. Co. v. CommissionerUnited States Tax Court · 1970

22 more not listed; retrieve them via the Exa API.

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