Legal Opinion
The Pennroad Corporation and Affiliated Companies v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided November 26, 1958No. 12597, 12598PublishedCited by 34 opinions
1Opinion of the Court
STALEY, Circuit Judge.
The sole question presented by these appeals is whether gains realized by the taxpayer on the sale of real estate during the years 1950, 1951, and 1952 are taxable as long-term capital gains or as ordinary income.
The facts, which are set forth in some detail in the opinion of the Tax Court, 1 may be summarized as follows:
The Pennroad Corporation is an investment company registered with the Securities and Exchange Commission as a closed-end management company pursuant to the Investment Company Act of 1940, 15 U.S.C.A. § 80a-l et seq. During the tax years in question,…
2Cases cited14 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
- Fackler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Stockton Harbor Industrial Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
9 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Joseph Lupowitz Sons, Inc. v. CommissionerCourt of Appeals for the Third Circuit · 1974
- Pointer v. CommissionerUnited States Tax Court · 1967
- Patterson v. BelcherCourt of Appeals for the Fifth Circuit · 1962
- Pleasant Summit Land Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1988
- Joseph B. And Josephine L. Simon v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Joseph B. And Josephine L. SimonCourt of Appeals for the Third Circuit · 1961
29 more not listed; retrieve them via the Exa API.