Legal Opinion
Birmingham v. Loetscher Co.
Court of Appeals for the Eighth Circuit
Decided April 11, 1951No. 14222PublishedCited by 19 opinions
1Opinion of the Court
GARDNER, Chief Judge.
This appeal is from a judgment against the Collector of Internal Revenue for the State of Iowa for a refund of certain taxes paid by the taxpayer under protest for the calendar years 1944 and 1946.
During the taxable years in ' question appellee was a personal holding company within the meaning of Section 501 of the Internal Revenue Code, 26 U.S.C.A. § 501. It filed its income, declared value, excess profits tax and personal holding company surtax returns on a cash and calendar year basis. In computing its Subchapter A net income for personal holding company surtax…
2Cases cited3 opinions
- Commissioner of Internal Revenue v. Clarion Oil Co.Court of Appeals for the D.C. Circuit · 1945
- Aramo-Stiftung v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Azzollini v. WatkinsCourt of Appeals for the Second Circuit · 1949
3Cited by19 opinions
- F. W. Drybrough v. Commissioner of Internal Revenue, L. N. Simpson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Lewyt Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- Estate of Goodall v. CommissionerCourt of Appeals for the Eighth Circuit · 1968
- Art Johnston v. Hugh Earle, Collector of Internal Revenue, Walter S. Shanks, Irwin Borthick and Irving H. CurranCourt of Appeals for the Ninth Circuit · 1957
- De Soto Securities Company v. Commission of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
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