General American Investors Co. v. Commissioner
United States Tax Court
Held, that payments received by a corporation because of "insiders'" profits pursuant to section 16 (b) of the Securities Exchange Act of 1934 and section 30 (f) of the Investment Company Act of 1940 constituted ordinary income to the corporation under section 22 (a), I. R. C.Park & Tilford Distillers Corporation v. United States (Ct. Cl.), 107 F. Supp. 941.
1Opinion of the Court
OPINION.
Black, Judge:
The applicable statutes in this proceeding are section 22 (a) of the Internal Revenue Code, section 30 (f) of the Investment Company Act of 1940, 54 Stat. 837, 15 U. S. C. section 80a-29 (f) and section 16 (b) of the Securities Exchange Act of 1934, 48 Stat. 896, 15 U. S. C. section 78p (b). Section 22 (a) of the Code is so familiar that it is unnecessary to incorporate it herein. The other two applicable statutory provisions are printed in the margin.1
The only question presented is whether amounts which were paid to the petitioner in 1948 by certain persons under…
Also in this document: Concurrence.
2Cases cited8 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Edwards v. Cuba RailroadSupreme Court of the United States · 1925
- Brown Shoe Co. v. CommissionerSupreme Court of the United States · 1950
- Texas & Pacific Ry. Co. v. United StatesSupreme Court of the United States · 1932
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3Cited by12 opinions
- General American Investors Co. v. CommissionerSupreme Court of the United States · 1955
- Commissioner of Internal Revenue v. Glenshaw Glass Co. Commissioner of Internal Revenue v. William Goldman Theatres, IncCourt of Appeals for the Third Circuit · 1954
- Commissioner of Internal Revenue v. Obear-Nester Glass CompanyCourt of Appeals for the Seventh Circuit · 1954
- Concord Village, Inc. v. CommissionerUnited States Tax Court · 1975
- William Goldman Theatres v. CommissionerUnited States Tax Court · 1953
7 more not listed; retrieve them via the Exa API.