Legal Opinion

Uncasville Mfg. Co. v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided February 1, 1932No. 52PublishedCited by 55 opinions

1Opinion of the Court

L. HAND, Circuit Judge.

The petitioner was a company making cotton cloth (denim) in two factories in Connecticut and keeping its books on an accrual basis. It returned its income taxes for the years 1916,1917, 1918, 1919, 1920, and 1922, and asserts that the Commissioner assessed deficiencies for each year, to review which it filed two petitions with the Board of Tax Appeals. The Board held that, as the Commissioner had assessed no deficiency for 1917, it had no jurisdiction for that year and entered an order fixing the deficiencies only for 1916, 1918, 1919, 1920 and 1922. As the question of…

2Cases cited13 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Phillips v. CommissionerSupreme Court of the United States · 1931
  3. Lucas v. American Code Co.Supreme Court of the United States · 1930
  4. The ConquerorSupreme Court of the United States · 1897
  5. Head v. HargraveSupreme Court of the United States · 1882

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3Cited by55 opinions

  1. Harrold v. Commissioner of Internal Revenue. Cromling v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1951
  2. Reading & Bates Corp. v. United StatesUnited States Court of Federal Claims · 1998
  3. Guardian Investment Corporation v. Robert L. Phinney, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
  4. Baltimore & OR Co. v. Commissioner of Internal Rev.Court of Appeals for the Fourth Circuit · 1935
  5. William B. Breland v. United States of America, United States of America v. William B. BrelandCourt of Appeals for the Fifth Circuit · 1963

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