Legal Opinion
Mills, Incorporated v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided December 4, 1957No. 5272PublishedCited by 4 opinions
1Opinion of the Court
MAGRUDER, .Chief Judge.
We have on review a decision of the Tax Court, entered March 8, 1957, determining that there is a deficiency in the taxpayer’s personal holding company surtax in the amount of $43,172.-81 for the taxable year 1949.
Reference to the plain and inescapable language of the Internal Revenue Code compels us to conclude that this decision by the Tax Court was wrong. Originally the Tax Court agreed with the contentions of the taxpayer in the case at bar. Alworth v. Commissioner, 38 B.T.A. 656 (1938); Clarion Oil Co. v. Commissioner, 1943, 1 T.C. 751. But the Tax Court’s decision…
2Cases cited11 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
- Commissioner of Internal Revenue v. Clarion Oil Co.Court of Appeals for the D.C. Circuit · 1945
- Aramo-Stiftung v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
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3Cited by4 opinions
- Estate of Goodall v. CommissionerCourt of Appeals for the Eighth Circuit · 1968
- Arc Realty Co. v. CommissionerUnited States Tax Court · 1960
- Estate of Robert A. Goodall, Deceased, C. M. Goodall v. Commissioner of Internal Revenue, Estate of Robert A. Goodall, Deceased, Clarice M. Goodall v. Commissioner of Internal Revenue, (Two Cases). Estate of Robert A. Goodall, Deceased, Clarice M. Goodall, and Clarice M. Goodall v. Commissioner of Internal Revenue, C. M. Goodall v. Commissioner of Internal Revenue, Good-All Electric Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1968
- Arc Realty Co. v. CommissionerUnited States Tax Court · 1960