Legal Opinion
Newman & Co. v. United States
Court of Appeals for the Second Circuit
Decided March 4, 1970No. Nos. 4, 5 and 6, Dockets 33020, 33021 and 33022PublishedCited by 4 opinions
1Opinion of the Court
J. JOSEPH SMITH, Circuit Judge.
This is an appeal by Newman & Company, a domestic partnership, nominal shareholder in three domestic corporations (Amitas, Sulectra and BSC) as nominee of three nonresident foreign corporations (Sofina, Solee and Services) from summary judgment in the United States District Court for the Southern District of New York, Charles H. Tenney, Judge, 290 F.Supp. 170 (S.D.N.Y.1968), upholding a deficiency assessment for federal income tax with respect to dividends distributed to Sofina, Solee and Services in the years 1954 through 1958. We find error and reverse and…
2Cases cited4 opinions
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Richard T. Graham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Fabreeka Products Company v. Commissioner of Imternal Revenue, Sadie S. Friedman v. Commissioner of Internal Revenue, Jack L. Sherman v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1961
- Newman & Co. v. United StatesDistrict Court, S.D. New York · 1968
3Cited by4 opinions
- Domtar Newsprint Sales Limited v. The United StatesUnited States Court of Claims · 1970
- Central De Gas De Chihuahua, S.A. v. CommissionerUnited States Tax Court · 1994
- Central De Gas De Chihuahua, S.A. v. CommissionerUnited States Tax Court · 1994
- Newman & Company v. United StatesCourt of Appeals for the Second Circuit · 1970