Legal Opinion
Utility Appliance Corporation, a Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 5, 1958No. 15369PublishedCited by 6 opinions
1Opinion of the Court
JERTBERG, District Judge.
This is a petition for a review of the decision of the Tax Court, and involves a determination of the Federal excess profits tax for the calendar year 1944.
The Commissioner has expressed some doubt as to the jurisdiction of this Court to review the decision of the Tax Court because of the prohibition against appellate review contained in Section 732(c) of the 1939 Internal Revenue Code, 26 U.S.C.A. Excess Profits Taxes, § 732(e). This section provides:
“If in the determination of the tax liability under this subchapter the determination of any question is necessary…
2Cases cited4 opinions
- United States v. Garbutt Oil Co.Supreme Court of the United States · 1938
- May Seed and Nursery Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1957
- St. Louis Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Lockhart Creamery v. CommissionerUnited States Tax Court · 1952
3Cited by6 opinions
- Headline Publications, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1959
- Worldwide Equipment of TN, Inc. v. United StatesCourt of Appeals for the Sixth Circuit · 2017
- Universal Pictures Co. v. United StatesDistrict Court, S.D. New York · 1964
- Gillette Co. v. CommissionerUnited States Tax Court · 1961
- Sprague Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1964
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