Legal Opinion
Commissioner v. Scottish American Investment Co.
Supreme Court of the United States
Decided January 2, 1945No. Nos. 52 to 54 and 220 to 222PublishedCited by 211 opinions
1Opinion of the CourtJustice Murphy
We are confronted here with another aspect of the problem of the judicial reviewability of Tax Court determinations.
The three taxpayers involved in these cases are investment trusts organized under the laws of Great Britain, with principal offices in Edinburgh, Scotland. Each is engaged in the business of investing the funds of its security holders for the primary purpose of deriving income from investments. The Tax Court, formerly known as the Board of Tax Appeals, has held that these taxpayers had an “office or place of business” within the United States during the four years in question…
2Cases cited8 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Wilmington Trust Co. v. HelveringSupreme Court of the United States · 1942
- BW Jones Trust v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1943
3 more not listed; retrieve them via the Exa API.
3Cited by211 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
206 more not listed; retrieve them via the Exa API.