Legal Opinion
Southwest Natural Gas Co. v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided May 30, 1951No. 13379_1PublishedCited by 38 opinions
1Opinion of the Court
RUSSELL, Circuit Judge.
The correctness of asserted deficiencies for corporate income tax for the year 1941 and of declared value excess profits tax and excess profits tax for 1942 due by Southwest Natural Gas Company depends upon whether a merger of Peoples Gas & Fuel Corporation with the taxpayer, effected in accordance with the laws of Delaware, was a sale, as asserted by the Commissioner, or a “reorganization” within the terms of Section 112(g) of the Internal Revenue Code,1 as contended by the taxpayer. The parties so stipulated the issue in the Tax Court.2 That Court upheld the…
2Cases cited9 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Bazley v. CommissionerSupreme Court of the United States · 1947
- Commissioner of Internal Revenue v. Gilmore's EstateCourt of Appeals for the Third Circuit · 1942
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3Cited by38 opinions
- American Potash & Chemical Corporation v. The United StatesUnited States Court of Claims · 1968
- Edmondson v. Allen-Russell Ford, Inc.Court of Appeals for the Fifth Circuit · 1978
- Paulsen v. CommissionerSupreme Court of the United States · 1985
- United States v. Adkins-Phelps, IncorporatedCourt of Appeals for the Eighth Circuit · 1968
- Superior Coach of Florida, Inc. v. CommissionerUnited States Tax Court · 1983
33 more not listed; retrieve them via the Exa API.