Legal Opinion
Robinette v. Commissioner
Court of Appeals for the Ninth Circuit
Decided March 19, 1945No. 10908PublishedCited by 6 opinions
1Opinion of the Court
BONE, Circuit Judge.
This case presents a question framed by the Commissioner of Internal Revenue as follows:
“A parent corporation, within the scope of Section 112(b) (6) of the Revenue Act of 1936 completely liquidated a wholly owned subsidiary having earnings or profits accumulated after February 28, 1913. In 1939 the parent made a distribution to its shareholders. Was the distribution made from the parent's earnings or profits under Section 115(a) and (h) of the Internal Revenue Code?”
The principal issue is whether the rule in Commissioner v. Sansome, 2 Cir., 60 F.2d 931, cert. denied 287…
2Cases cited18 opinions
- Welch v. HenrySupreme Court of the United States · 1938
- Commissioner of Internal Revenue v. SansomeCourt of Appeals for the Second Circuit · 1932
- BERETTA v. COMMISSIONERUnited States Tax Court · 1942
- Lawler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1935
- Beretta v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1944
13 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Commissioner v. PhippsSupreme Court of the United States · 1949
- James P. Neill v. Robert L. Phinney, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Sheehan v. DanaCourt of Appeals for the Eighth Circuit · 1947
- United States v. PownallDistrict Court, S.D. California · 1946
- Mansfield v. United StatesUnited States Court of Claims · 1958
1 more not listed; retrieve them via the Exa API.