Legal Opinion
Commissioner of Internal Revenue v. Stevens
Court of Appeals for the Second Circuit
Decided June 24, 1935No. 382PublishedCited by 11 opinions
1Opinion of the Court
MANTON, Circuit Judge.
The respondent was a member of the stock brokerage firm of Stevens & Legg. There were seven partners, six of whom were members of the stock exchange. Respondent claimed, and the Board of Tax Appeals agreed, that they were dealers in securities, and, as such, were permitted to inventory, at market value, their unsold securities on hand for the calendar years 1929 and 1930 in computing their net income for those years. Revenue Act of 1928, c. 852, 45 Stat. 791 (26 USCA § 2001 et seq.).
The Act provides: “Whenever in the opinion of the Commissioner the use of inventories is…
2Cases cited4 opinions
- United States v. United Verde Copper Co.Supreme Court of the United States · 1905
- Seeley v. HelveringCourt of Appeals for the Second Circuit · 1935
- Harriman National Bank v. Com'r of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Clicquot Club Co. v. United StatesDistrict Court, D. Massachusetts · 1926
3Cited by11 opinions
- Gruver v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1944
- Schafer v. HelveringCourt of Appeals for the D.C. Circuit · 1936
- Stephen Marrin and Jane Marrin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
- Leach Corp. v. BlacklidgeDistrict Court, N.D. Illinois · 1938
- Vaughan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1936
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