Legal Opinion
Pinellas Ice & Cold Storage Co. v. Com'r of Int. Rev.
Court of Appeals for the Fifth Circuit
Decided March 29, 1932No. 6347PublishedCited by 14 opinions
1Opinion of the Court
FOSTER, Circuit Judge.
In December, 1026, petitioner, the Pinel-las lee & Cold Storage Company, a Florida corporation, disposed of substantially all its property to another corporation. Treating the transaction as a reorganization of the company, in making returns for 1926, petitioner assumed that, under the provisions of section 203, Revenue Aet of 1926 (26 USCA § 934), no taxable profit had been derived from the transfer. The Commissioner of Internal Revenue disagreed with this and determined that a taxable profit of $552,144.12 had resulted from a sale of assets. A deficiency of $74,673.50…
2Cases cited1 opinion
- Royal Palm Soap Co. v. Seaboard Air Line Ry. Co.Court of Appeals for the Fifth Circuit · 1924
3Cited by14 opinions
- Cortland Specialty Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1932
- West Texas Refining & D. Co. v. Commissioner of Int. Rev.Court of Appeals for the Tenth Circuit · 1933
- Ahles Realty Corp. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1934
- C. H. Mead Coal Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1934
- Miller v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1936
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