Legal Opinion

Palcar Real Estate Co. v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided November 3, 1942No. 12274PublishedCited by 14 opinions

1Opinion of the Court

JOHNSEN, Circuit Judge.

The Board of Tax Appeals redetermined income tax deficiencies against petitioner for the years 1934, 1935 and 1936, on the rents which the corporation had collected from a piece of real estate to which it held the record title, and petitioner seeks to reverse the Board’s decision on the ground that the corporation’s title to the property was purely nominal and that it was simply serving as a conduit for the payment of the rents to its stockholders as the beneficial owners.

The evidence taken before the Board is not contained in the record before us, so the review here…

2Cases cited9 opinions

  1. Higgins v. SmithSupreme Court of the United States · 1940
  2. United States v. PhellisSupreme Court of the United States · 1921
  3. Peabody v. EisnerSupreme Court of the United States · 1918
  4. United States v. Brager Building & Land CorporationCourt of Appeals for the Fourth Circuit · 1941
  5. Watson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942

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

3Cited by14 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
  3. Wirtz v. Local Union 169, International Hod Carriers', Building & Common Laborers' Union of America, AFL-CIODistrict Court, D. Nevada · 1965
  4. Central Paper Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1952
  5. Given v. CommissionerCourt of Appeals for the Eighth Circuit · 1956

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

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