Hugh A. O'Neill and Elizabeth O'Neill v. United States
Court of Appeals for the Sixth Circuit
1Opinion of the Court
HARRY PHILLIPS, Circuit Judge.
The central question before this Court is whether a professional business organization which is a corporation under state law is a corporation for federal tax purposes wthin the meaning of 26 U.S.C. § 7701(a) (3), which provides that: “The term ‘corporation’ includes associations, joint-stock companies, and insurance companies.” We hold that it is.
The United States appeals from a judgment in an income tax refund action. District Judge Thomas D. Lambros rendered judgment in favor of the taxpayer, after hearing the case on stipulated facts. The opinion of the…
2Cases cited30 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
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3Cited by36 opinions
- Leroux's Billyle Supper Club v. MaOhio Court of Appeals · 1991
- In the Matter of James v. Pappas, Bankrupt. Merchants National Bank & Trust Company of Indianapolis v. James v. PappasCourt of Appeals for the Seventh Circuit · 1981
- Continental Oil Company v. BurnsDistrict Court, D. Delaware · 1970
- Roubik v. CommissionerUnited States Tax Court · 1969
- Howard A. Kurzner and C. A. Kurzner v. United StatesCourt of Appeals for the Fifth Circuit · 1969
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