Legal Opinion
Randolph Products Co. v. Manning
Court of Appeals for the Third Circuit
Decided July 7, 1949No. 9766PublishedCited by 33 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
The single issue presented by this appeal is whether the income of a corporation derived exclusively from the rental of its property to a partnership consisting of husband atid wife who own all of the corporation’s capital stock, is “personal holding -company income” within the meaning of Section 502(f), Internal Revenue Code, 26 U.S.C.A. § 502(f).
The facts as found by the District Court may be summarized as follows:
The taxpayer is a corporation organized under the laws of New Jersey. It was the owner of a factory building which was rented to Wendell G. Randolph and…
2Cases cited7 opinions
- Neuberger v. CommissionerSupreme Court of the United States · 1940
- Commissioner of Internal Revenue v. WhitneyCourt of Appeals for the Second Circuit · 1948
- Jennings v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1940
- Scherf v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1947
- Johnston v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1936
2 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- United States v. ShapiroCourt of Appeals for the Eighth Circuit · 1949
- Girard Trust Co. v. United StatesCourt of Appeals for the Third Circuit · 1950
- Western Transmission Corp. v. CommissionerUnited States Tax Court · 1952
- Fourth & Railroad Realty Co. v. CommissionerUnited States Tax Court · 1955
- O. Falk's Dep't Store, Inc. v. CommissionerUnited States Tax Court · 1953
28 more not listed; retrieve them via the Exa API.