Legal Opinion

The Smoot Sand & Gravel Corporation v. Commissioner of Internal Revenue

Court of Appeals for the Fourth Circuit

Decided March 8, 1957No. 7265_1PublishedCited by 81 opinions

1Opinion of the Court

SOBELOFF, Circuit Judge.

This is a petition for review of a decision of the Tax Court of the United States upholding an assessment made by the Commissioner of Internal Revenue against the Petitioner, the Smoot Sand and Gravel Corporation, for surtaxes under Section 102(a) of the Internal Reve nue Code of 1939. 1 Liability rests upon the finding that the corporation was availed of in the years 1945-1950 for the purpose of preventing the imposition of surtax upon its sole stockholder, Columbia Sand and Gravel Company, Inc., and upon L. E. Smoot, owner of all the common stock of the latter…

2Cases cited7 opinions

  1. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  2. Helvering v. Chicago Stock Yards Co.Supreme Court of the United States · 1943
  3. J. L. Goodman Furniture Co. v. CommissionerUnited States Tax Court · 1948
  4. JM Perry & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1941
  5. K O M A, Inc. v. Commissioner of Internal Revenue. Tulsa Broadcasting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951

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

3Cited by81 opinions

  1. The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
  2. John P. Scripps Newspapers v. CommissionerUnited States Tax Court · 1965
  3. Bremerton Sun Publishing Co. v. CommissionerUnited States Tax Court · 1965
  4. American Metal Products Corporation v. Commissioner of Internal Revenue, Adler Metal Products Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
  5. American Metal Products Corp. v. CommissionerUnited States Tax Court · 1960

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

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