Legal Opinion

C. F. Mueller Company v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided May 18, 1973No. 71-1860, 71-1861PublishedCited by 3 opinions

1Opinion of the Court

OPINION OF THE COURT

STALEY, Circuit Judge.

These are appeals from decisions of the Tax Court that certain payments made by' appellant C. F. Mueller Company (“Mueller”) in the years 1959 through 1963 to the Law Center Foundation (“Foundation”) were in substance nondeductible dividend distributions rather than charitable contributions. 1 In order to resolve the questions presented on appeal, we must examine the relationship between Mueller and the Foundation. The following is a summary of the Tax Court’s detailed findings in that regard.

On August 21, 1947, Mueller was incorporated under the laws…

2Cases cited14 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Helvering v. HorstSupreme Court of the United States · 1940
  3. C. F. Mueller Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
  4. Joseph R. Holsey and Eleanor T. Holsey v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
  5. Elizabeth N. B. Ferro v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957

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3Cited by3 opinions

  1. L. C. Bohart Plumbing & Heating Co. v. CommissionerUnited States Tax Court · 1975
  2. Alabama Central Credit Union v. United StatesDistrict Court, N.D. Alabama · 1986
  3. L. C. Bohart Plumbing & Heating Co. v. CommissionerUnited States Tax Court · 1975

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