Legal Opinion
Commissioner of Internal Revenue v. Roger W. Pope
Court of Appeals for the First Circuit
Decided January 8, 1957No. 5158PublishedCited by 14 opinions
1Opinion of the Court
WOODBURY, Circuit Judge.
This petition by the Commissioner of Internal Revenue for review of a decision of the Tax Court of the United States presents a single issue on undisputed facts.
The taxpayer owned a substantial majority of the stock of two separate and distinct corporations, both of which had earned surpluses in six figures because neither had ever paid any substantial dividends but had retained its earnings for expansion. In November, 1949, the taxpayer sold 83 of his shares in one corporation to the other for $25,000 in order to obtain funds for investment' in a business quite…
2Cases cited3 opinions
- Keefe, Collector v. CoteCourt of Appeals for the First Circuit · 1954
- Commissioner of Internal Revenue v. Trustees Common Stock John Wanamaker PhiladelphiaCourt of Appeals for the Third Circuit · 1949
- Trustees Common Stock John Wanamaker Philadelphia Under Will of Wanamaker v. CommissionerUnited States Tax Court · 1948
3Cited by14 opinions
- E. Keith Owens v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
- Highland Hills Swimming Club, Inc., a Corporation v. Earl R. Wiseman, District Director Internal RevenueCourt of Appeals for the Tenth Circuit · 1959
- Trianon Hotel Co. v. CommissionerUnited States Tax Court · 1958
- United States v. R. Perry Collins, (Two Cases)Court of Appeals for the First Circuit · 1962
- Syms Corp. v. Commissioner of RevenueMassachusetts Supreme Judicial Court · 2002
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