Legal Opinion
Commissioner of Internal Revenue v. Smith
Court of Appeals for the Second Circuit
Decided June 9, 1943No. 95PublishedCited by 15 opinions
1Opinion of the Court
AUGUSTUS N. HAND, Circuit Judge.
The first question before us is whether dividends of the Chrysler Corporation to the amount of $92,667, paid in the year 1929, and dividends of the Chrysler Corporation to the amount of $82,740, and of the Hudson Motor Car Company to the amount of $6,175, paid in the year 1930, should be assessed as income of the taxpayer, John Thomas Smith, rather than as income of Innisfail Corporation, of which he was the sole stockholder.
Innisfail was a New Jersey corporation owned and controlled by the taxpayer. The Tax Court made a finding that the “purpose of the…
2Cases cited5 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Higgins v. SmithSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Brown v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
3Cited by15 opinions
- Bass v. CommissionerUnited States Tax Court · 1968
- Noonan v. CommissionerUnited States Tax Court · 1969
- United States v. John C. Bruswitz and Edward C. KoenkeCourt of Appeals for the Second Circuit · 1955
- Delaney v. GardnerCourt of Appeals for the First Circuit · 1953
- National Lead Co. v. CommissionerUnited States Tax Court · 1963
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