Legal Opinion
Commissioner of Internal Revenue v. Irving Gordon and Margaret Gordon, Irving Gordon and Margaret Gordon v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided July 26, 1967No. 30572_1PublishedCited by 20 opinions
1Opinion of the Court
MOORE, Circuit Judge.
The taxpayers, Irving and Margaret Gordon (husband and wife) in 1961 owned 1,540 shares of Pacific Telephone and Telegraph Company (Pacific) common stock. Their stock certificate represented a fractional part, in theory at least, of all the assets of this company. Although collectively the stockholders owned these assets, the corporate form was not within the control of the individual stockholder but, for all practical purposes, in the control of the company's management. Therefore, when Pacific decided to have its assets held by two corporations instead of one, the…
2Cases cited19 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. HorstSupreme Court of the United States · 1940
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
14 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Commissioner v. GordonSupreme Court of the United States · 1968
- Gerald R. Redding and Dorothy M. Redding and Thomas W. Moses and Anne M. Moses v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
- Redding v. CommissionerUnited States Tax Court · 1979
- Irving Gordon and Margaret Gordon v. Cmmissioner of Intenal RevenueCourt of Appeals for the Second Circuit · 1970
- Baan v. CommissionerUnited States Tax Court · 1969
15 more not listed; retrieve them via the Exa API.