Legal Opinion

Mayflower Investment Company v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided December 26, 1956No. 15953PublishedCited by 24 opinions

1Opinion of the Court

TUTTLE, Circuit Judge.

This petition for review from a decision of the Tax Court presents two questions: (1) Whether the court properly found that the sum of $12,300 received by petitioner in 1950 was interest instead of operating profit; and (2) Whether the failure of petitioner to file a personal holding company return for the years 1947 through 1950 was properly held by the Tax Court not to be due to reasonable cause and due to willful neglect and therefore warranted the imposition of the negligence penalty for failure to file under Section 291 of the Internal Revenue Code of 1939. 1

The…

2Cases cited11 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  3. Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
  4. Southeastern Finance Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
  5. Safety Tube Corp. v. CommissionerUnited States Tax Court · 1947

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

3Cited by24 opinions

  1. Giesen v. United StatesDistrict Court, W.D. Wisconsin · 1973
  2. R. A. Bryan and Ruby M. Bryan, C. B. McNairy and Rowena A. McNairy W. H. Weaver and Edith H. Weaver v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
  3. Herald A. O'Neill and G. Evelyn O'neill, His Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
  4. Merian Rohrabaugh, Administratrix of the Estate of John T. Lemen, Sr., Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1979
  5. Co-Operative Grain & Supply Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1969

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

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