Legal Opinion
Parsons v. Smith
Court of Appeals for the Third Circuit
Decided March 27, 1958No. Nos. 12299-12301PublishedCited by 7 opinions
1Opinion of the Court
HASTIE, Circuit Judge.
These are appeals by taxpayers, who are partners in a business, from a judgment of the district court denying their several claims for refunds of income taxes paid upon their respective distributable shares of certain partnership income derived from coal mining. The appellants can prevail only if the involvement of the partnership, hereinafter called Parsons, in a strip mining enterprise was such as to entitle the partners to deduct a depletion allowance, pursuant to Sections 23(m) and 114(b) of the Internal Revenue Code of 1939, 26 U.S.C. §§ 23(m), 114(b), as…
2Cases cited9 opinions
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Ruston v. CommissionerUnited States Tax Court · 1952
- Commissioner of Internal Revenue v. The Mammoth Coal CompanyCourt of Appeals for the Third Circuit · 1956
- Emil Usibelli and Rose P. Usibelli v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Weirton Ice and Coal Supply Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1956
4 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Denise Coal Co. v. CommissionerCourt of Appeals for the Third Circuit · 1959
- Denise Coal Company v. Commissioner of Internal Revenue, Estate of Charles J. Margiotti, Deceased. Denise Z. Margiotti v. Commissioner of Internal Revenue, Juliette C. Suto (Formerly Juliette C. Margiotti) v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Huss v. SmithCourt of Appeals for the Third Circuit · 1958
- Stallard v. United StatesDistrict Court, W.D. Virginia · 1958
- Emory W. Parsons and Erma M. Parsons v. Francis R. Smith, Former Collector of Internal Revenue for the First District of Pennsylvania. Howard H. Parsons and Martha Parsons v. Francis R. Smith, Former Collector of Internal Revenue for the First District of Pennsylvania. Lawrence H. Parsons and Grace E. Parsons v. Francis R. Smith, Former Collector of Internal Revenue for the First District of PennsylvaniaCourt of Appeals for the First Circuit · 1958
2 more not listed; retrieve them via the Exa API.