Legal Opinion

A--C Inv. Asso. v. Commissioner

United States Board of Tax Appeals

Decided November 4, 1931No. Docket Nos. 43192, 49682PublishedCited by 6 opinions

Held that the petitioning organization was an association taxable as a corporation.

1Opinion of the Court

*588OPINION.

Van Fossan:

The fundamental issue in these proceedings is whether or not the petitioner was an association taxable as a corporation.

The word “ association ” as used in the revenue acts is a term “used throughout the United States to signify a body of persons united *589without a charter, but upon the methods and forms used by incorporated bodies for the prosecution of some common enterprise. * * * An organized but unchartered body analagous to but distinguished from a corporation.” Hecht v. Malley, 265 U. S. 144.

The petitioner was an unincorporated body of persons. The petitioner’s plan,…

2Cases cited4 opinions

  1. Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
  2. Hecht v. MalleySupreme Court of the United States · 1924
  3. Bank of Redemption v. BostonSupreme Court of the United States · 1888
  4. United States v. WilliamsSupreme Court of the United States · 1929

3Cited by6 opinions

  1. Savings Feature of Relief Dep't v. CommissionerUnited States Board of Tax Appeals · 1935
  2. Leszczynski v. CommissionerUnited States Board of Tax Appeals · 1933
  3. A--C Inv. Asso. v. CommissionerUnited States Board of Tax Appeals · 1931
  4. Leszczynski v. CommissionerUnited States Board of Tax Appeals · 1933
  5. Savings Feature of Relief Dep't v. CommissionerUnited States Board of Tax Appeals · 1935

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