Legal Opinion

E. R. Wagner Manufacturing Co. v. United States

District Court, E.D. Wisconsin

Decided December 8, 1964No. 63-C-73PublishedCited by 2 opinions

1Opinion of the Court

GRUBB, District Judge.

Plaintiff, E. R. Wagner Manufacturing Company, a Wisconsin corporation, hereinafter called the “Taxpayer,” seeks to recover income taxes paid for the year 1959, pursuant to deficiencies assessed in respect to deductions disallowed by the Internal Revenue Service. The action was tried to the court. There is no issue as to jurisdiction or venue. The parties have stipulated to substantial portions of the record.

Two questions are presented in this case:

1. Whether payments to stockholders of Taxpayer, made pursuant to certain stock repurchase agreements, constitute payments…

2Cases cited10 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Autenreith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
  4. Commissioner v. Philadelphia Transportation Co.Supreme Court of the United States · 1949
  5. Commissioner of Internal Revenue v. Philadelphia Transp. Co.Court of Appeals for the Third Circuit · 1949

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3Cited by2 opinions

  1. Allen Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1969
  2. Vesuvius Crucible Co. v. CommissionerUnited States Tax Court · 1965

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