Legal Opinion
Fairfield S. S. Corp. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided August 9, 1946No. 222, Docket 20115PublishedCited by 26 opinions
1Opinion of the Court
L. HAND, Circuit Judge.
This is a petition to review an order of the Tax Court, affirming a deficiency assessment against the Fairfield Steamship Company, based upon a gain “realized” upon the sale of a ship in 1940. The Fair-field Company was a corporation, all of whose shares were owned by another corporation, the Atlantic Coast Shipping Company, and the validity of the assessment turns upon which of the two companies made the sale. Concededly the Fairfield Company owned the ship and transferred it to the Atlantic Company, which sold it to a third party; if the transfer to the Atlantic…
2Cases cited2 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
3Cited by26 opinions
- United States v. Lynch. Lynch v. United StatesCourt of Appeals for the Ninth Circuit · 1951
- Commissioner of Int. Rev. v. Transport Trad. & Term. Corp.Court of Appeals for the Second Circuit · 1949
- Century Electric Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1951
- Gensinger v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
- Jordan Marsh Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1959
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