Legal Opinion

Commissioner of Internal Revenue v. General MacHinery Corp.

Court of Appeals for the Sixth Circuit

Decided April 7, 1938No. 7485PublishedCited by 17 opinions

1Opinion of the Court

SIMONS, Circuit Judge.

As in Joseph & Feiss Co. v. Commissioner, 6 Cir., 70 F.2d 804, decided by us May 7, 1934, in accord with Arnold Constable Corp. v. Commissioner, 2 Cir., 69 F.2d 788, and as in Helvering, Commissioner, v. Morgan’s, Inc., et al., 293 U.S. 121, 55 S.Ct. 60, 79 L.Ed. 232, the question is whether two periods in the same calendar or fiscal year for which affiliated corporations are required to make income tax returns constitute two “taxable years” within the meaning of the sections of the revenue acts which permit a taxpayer suffering a loss in any taxable year to deduct it…

2Cases cited6 opinions

  1. Helvering v. Morgan's, Inc.Supreme Court of the United States · 1934
  2. Corner Broadway-Maiden Lane v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1935
  3. Arnold Constable Corp. v. CommissionerCourt of Appeals for the Second Circuit · 1934
  4. Palomas Land & Cattle Co. v. CommissionerCourt of Appeals for the Ninth Circuit · 1937
  5. Wishnick-Tumpeer, Inc. v. HelveringCourt of Appeals for the D.C. Circuit · 1934

1 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. American Standard, Inc. v. United StatesUnited States Court of Claims · 1979
  2. McCann L. REID, Plaintiff-Appellant and Cross-Appellee, v. MEMPHIS PUBLISHING COMPANY, Defendant-Appellee and Cross-AppellantCourt of Appeals for the Sixth Circuit · 1975
  3. Wolter Construction Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
  4. United States v. Peabody Co.Court of Appeals for the Sixth Circuit · 1939
  5. Union Carbide Corp. v. United StatesUnited States Court of Claims · 1979

12 more not listed; retrieve them via the Exa API.

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