Legal Opinion
B. Forman Co. v. Commissioner
Court of Appeals for the Second Circuit
Decided January 10, 1972No. Nos. 768-771, Dockets 35434, 35839, 71-1026, 71-1027PublishedCited by 38 opinions
1Opinion of the Court
ZAVATT, District Judge.
These are cross-appeals from a decision of the Tax Court, 54 T.C. 913 (1970), holding (1) that 26 U.S.C. § 482 (the Internal Revenue Code of 1954, hereinafter the “Code”) did not authorize the Commissioner to allocate to B. Forman Co., Inc. (Forman) and McCurdy & Co., Inc. (McCurdy) (both referred to herein as taxpayers) interest income attributable to interest free loans made by the taxpayers to Midtown Holdings Corp. (Midtown), because of the absence of the requisite § 482 control of Midtown by the taxpayers; and (2) that annual payments of $75,000.00 each made by…
2Cases cited44 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Higgins v. SmithSupreme Court of the United States · 1940
39 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Bausch & Lomb Incorporated and Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Latham Park Manor, Inc. v. CommissionerUnited States Tax Court · 1977
- Crown v. CommissionerUnited States Tax Court · 1977
- Austin Co. v. CommissionerUnited States Tax Court · 1979
- Bunge Corp. v. Commissioner of RevenueSupreme Court of Minnesota · 1981
33 more not listed; retrieve them via the Exa API.