Legal Opinion

JM Perry & Co. v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided May 23, 1941No. 9662PublishedCited by 39 opinions

1Opinion of the Court

STEPHENS, Circuit Judge.

The Commissioner of Internal Revenue determined that the petitioner-taxpayer was subject to additional taxes for the years 1935 and 1936, as imposed by Section 102 of the Revenue Acts of 1934 and 1936 [c. 277, 48 Slat. 680, 26 U.S.C.A.int.Rev.Acts, page 690; c. 690, 49 Stat. 1648, 26 U.S.C. A. Int.Rev.Acts, page 851], The Board of Tax Appeals sustained the determination of the Commissioner, and the taxpayer seeks a reversal.

Section 102 of the 1936 Act provides, 1 so far as here applicable:

“(a) Imposition of tax. There shall be levied, coilected, and paid for each…

2Cases cited8 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  3. Bogardus v. CommissionerSupreme Court of the United States · 1937
  4. Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
  5. Commissioner of Internal Revenue v. Cecil B. De Mille Productions, Inc.Court of Appeals for the Ninth Circuit · 1937

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

3Cited by39 opinions

  1. William O'Dwyer and Sloan O'Dwyer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
  2. The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
  3. Crude Oil Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1947
  4. Leon J. Toledano and Esther C. Toledano v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
  5. Southern Ford Tractor Corp. v. CommissionerUnited States Tax Court · 1958

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

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