Legal Opinion
Helvering v. Suffolk Co.
Court of Appeals for the Fourth Circuit
Decided June 12, 1939No. 4451PublishedCited by 7 opinions
1Opinion of the Court
SOPER, Circuit Judge.
This petition for review requires an interpretation of section 119 of the Revenue Act of 1932, 47 Stat. 169, 208, 26 U. S.C.A. § 119, relating to income from sources within and sources without the United States, so that the taxable income of the Suffolk Company, Ltd., a corporation organized under the laws of Newfoundland, from sources within the United States in the tax year of 1933 may be determined.
On February 19, 1932, pursuant to a plan of reorganization, the taxpayer exchanged its entire capital stock for substantially all of the assets of Blair & Company, Inc., a…
2Cases cited2 opinions
- De Stuers v. CommissionerUnited States Board of Tax Appeals · 1932
- N. v. Koninklijke Hollandische Lloyd v. CommissionerUnited States Board of Tax Appeals · 1936
3Cited by7 opinions
- Associated Telephone and Telegraph Company, and Cross v. United States of America, and CrossCourt of Appeals for the Second Circuit · 1962
- Bank of America v. United StatesUnited States Court of Claims · 1982
- Trust of Welsh v. CommissionerUnited States Tax Court · 1951
- San Juan Trading Co. v. Secretario de HaciendaSupreme Court of Puerto Rico · 1958
- Helvering v. BoekmanCourt of Appeals for the Second Circuit · 1939
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