Legal Opinion

Hay v. Commissioner of Internal Revenue

Court of Appeals for the Fourth Circuit

Decided November 13, 1944No. 5269PublishedCited by 20 opinions

1Opinion of the Court

SOPER, Circuit Judge.

The petition for review questions a decision of the Tax Court which held that William C. Hay, a British subject, was liable to an additional income tax in excess of $600,000 for tlie year 1937 upon the liquidation of William C. Hay, Ltd., a California corporation. There is no serious question of fact since the findings of the Tax Court were supported by abundant evidence, which is summarized in the following recital: Hay was born a British subject in Canada in 1884. He took up his residence in Los Angeles in 1914, and became a naturalized citizen oí the United States in…

2Cases cited9 opinions

  1. Higgins v. SmithSupreme Court of the United States · 1940
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Griffiths v. CommissionerSupreme Court of the United States · 1939
  4. Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
  5. Helvering v. Credit Alliance Corp.Supreme Court of the United States · 1942

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3Cited by20 opinions

  1. Dean v. CommissionerUnited States Tax Court · 1971
  2. A. Finkenberg's Sons, Inc. v. CommissionerUnited States Tax Court · 1951
  3. Bass v. CommissionerUnited States Tax Court · 1968
  4. Noonan v. CommissionerUnited States Tax Court · 1969
  5. Park Terrace, Inc. v. Phoenix Indemnity Co.Supreme Court of North Carolina · 1956

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