Legal Opinion

American Trans-Ocean Navigation Corporation v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided January 24, 1956No. 23468_1PublishedCited by 20 opinions

1Opinion of the Court

LUMBARD, Circuit Judge.

This is an appeal by the taxpayer from a decision of the Tax Court on stipulated facts 13 T.C.M. 839 (1954). The taxpayer is a New York corporation. In 1948 it organized a subsidiary, Amtron Tanker Corporation, for the purpose of acquiring a tanker from the United States Maritime Commission. The subsidiary was organized because the Commission said that a direct purchase by the taxpayer might violate the Commission’s regulations. The subsidiary purchased the tanker in 1948 and has engaged only in the business of operating that tanker. For 1948 and l949 the taxpayer and…

2Cases cited5 opinions

  1. Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
  2. Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
  3. Stanton Brewery v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
  4. S. Slater & Sons, Inc. v. WhiteCourt of Appeals for the First Circuit · 1941
  5. American Trans-Ocean Navigation Corp. v. CommissionerUnited States Tax Court · 1954

3Cited by20 opinions

  1. American Standard, Inc. v. United StatesUnited States Court of Claims · 1979
  2. Patten Fine Papers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1957
  3. Frelbro Corp. v. CommissionerUnited States Tax Court · 1961
  4. Union Carbide Corp. v. United StatesUnited States Court of Claims · 1979
  5. Electronic Sensing Products, Inc. v. CommissionerUnited States Tax Court · 1977

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API