Legal Opinion
Commissioner of Internal Revenue v. Seminole Manufacturing Company
Court of Appeals for the Fifth Circuit
Decided May 8, 1956No. 15739PublishedCited by 14 opinions
1Opinion of the Court
TUTTLE, Circuit Judge.
The question presented by this appeal is one that has been much litigated in the Tax Court and in the Courts of Appeals. The Tax Court has held consistently to one view and the appellate courts in at least eight cases have reversed. In one Circuit the Court of Appeals dismissed the appeal as being premature.
This is a petition for review of an order of the Tax Court in a proceeding authorized by § 732, 26 U.S.C.A., for re-determination of excess profits tax liability under the terms of § 722, 26 U.S.C.A., which, under circumstances there stated, provide abnormality…
2Cases cited10 opinions
- H. Fendrich, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1951
- Martin Weiner Corp. v. CommissionerUnited States Tax Court · 1954
- Commissioner of Internal Revenue v. The S. Frieder & Sons CompanyCourt of Appeals for the Third Circuit · 1955
- Commissioner of Internal Revenue v. Smith Paper, Inc.Court of Appeals for the First Circuit · 1955
- West Flagler Amusement Co. v. CommissionerUnited States Tax Court · 1954
5 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Louisville Builders Supply Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1961
- H. Fendrich, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1957
- The Brown Paper Mill Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- The Crowell-Collier Publishing Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Estate of Smith v. CommissionerCourt of Appeals for the Third Circuit · 1981
9 more not listed; retrieve them via the Exa API.