Legal Opinion
Commissioner of Internal Revenue v. General Gas & Electric Corp.
Court of Appeals for the Second Circuit
Decided July 16, 1934No. 410PublishedCited by 4 opinions
1Opinion of the Court
CHASE, Circuit Judge.
The facts are not in dispute. The respondent owned all of the capital stock of its subsidiary, General Finance Corporation, during 1924. In that year, General Finance Corporation said 7,300 shares of the convertible preferred stock of the respondent io purchasers other than members of the affiliated group. It had previously acquired this stock from nonmembers of the group for $227,662.26 less than the price for which it sold the stock. The Commissioner included in gross income this excess of the sale price over the cost or basis of the stock to the General Finance…
2Cases cited7 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Merchants' Loan & Trust Co. v. SmietankaSupreme Court of the United States · 1921
- Commissioner of Internal Revenue v. SA Woods MacH. Co.Court of Appeals for the First Circuit · 1932
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3Cited by4 opinions
- RJ Reynolds Tobacco Co. v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1938
- Consolidated Utilities Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1936
- Founders General Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
- Founders General Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935