Legal Opinion

Hightower v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided March 9, 1951No. 13310PublishedCited by 19 opinions

1Opinion of the Court

HUTCHESON, Chief Judge.

The Commissioner disallowed claimed rentals paid by Midway Liquor Company to Goodie-Goodie Restaurant, Inc., 1 as lessor, in its taxable years 1943 and 1944, allowing in lieu thereof $3,600 per year, and having determined deficiencies accordingly, notified the petitioner thereof as transferee, the two corporations having been dissolved.

The Tax Court, upon a full hearing on transferee’s petition for relief, sustained the determination, and petitioner is here insisting that in doing so it erred in law and in fact. We cannot agree.

The error in law asserted is the view of…

2Cases cited1 opinion

  1. J. H. Robinson Truck Lines, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950

3Cited by19 opinions

  1. Place v. CommissionerUnited States Tax Court · 1951
  2. American Metal Products Corp. v. CommissionerUnited States Tax Court · 1960
  3. Burford-Toothaker Tractor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  4. Estate of Albert D. Phillips, Deceased, Viola T. Chartrand, Formerly Viola T. Phillips, Administratrix v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
  5. South Texas Rice Warehouse Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966

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