Legal Opinion
Hartford-Empire Co. v. Com'r of Internal Revenue
Court of Appeals for the Second Circuit
Decided July 8, 1943No. 200PublishedCited by 17 opinions
1Opinion of the Court
L. HAND, Circuit Judge.
The Tax Court held that for the years 1932, 1933 and 1934, the taxpayer must use as a “basis” for the depreciation of certain patents which it owned, their cost to other corporations from which the taxpayer had acquired them; the taxpayer insisted that the proper “basis” was its own cost at the time of acquisition. The issues on which the question turns are two: (1) whether the Commissioner was estopped as to the “basis” by certain earlier orders of the Tax Court, which had assessed deficiencies against the taxpayer for the years 1923 to 1928, inclusive; (2) if he was…
2Cases cited8 opinions
- Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942
- Bingham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1939
- Hartford-Empire Co. v. CommissionerUnited States Board of Tax Appeals · 1932
3 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Fairmont Aluminum Co. v. CommissionerUnited States Tax Court · 1954
- Trapp v. United StatesCourt of Appeals for the Tenth Circuit · 1949
- Seiberling Rubber Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1948
- International Bldg. Co. v. United StatesCourt of Appeals for the Eighth Circuit · 1952
- Mather & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1949
12 more not listed; retrieve them via the Exa API.