Legal Opinion

Isbell Porter Co. v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided April 7, 1930No. 150PublishedCited by 8 opinions

1Opinion of the Court

AUGUSTUS N. HAND, Circuit Judge.

The question raised by this appeal is whether certain drawings belonging to the taxpayer should be treated as part of invested capital in' calculating the excess profits tax for 1919.

The business of the taxpayer was the manufacture and sale of machinery and apparatus for producing and purifying gas. In the course of this business it made many draw ings, (1) for work in process attributable to a particular job; (2) standard model drawings, tbe object of which was to bring apparatus up to date to meet conditions from year to year and from month to month; (3)…

2Cases cited4 opinions

  1. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  2. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  3. Reinecke v. SpaldingSupreme Court of the United States · 1930
  4. R. Hoe & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929

3Cited by8 opinions

  1. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  2. Underwood v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1932
  3. Union Pacific Railroad v. United StatesUnited States Court of Claims · 1975
  4. Askin & Marine Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
  5. Legg's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1940

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