Legal Opinion
Reilly Oil Co. v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided May 22, 1951No. 13202_1PublishedCited by 20 opinions
1Opinion of the Court
RUSSELL, Circuit Judge.
The sole issue in this case is whether the organization of petitioner for review in 1940 as a result of proceedings under Chapter X of the Bankruptcy Act, 11 U.S. C.A. 501 et seq., was a tax free reorganization within the terms of Section 112 of the Internal Revenue Code. 26 U.S.C.A. § 112. The Tax Court, five judges dissenting, held that the transaction came within the terms of the statute and therefore upheld the Commissioner’s determination that the petitioner’s basis for cost in computing depletion was the cost basis of its predecessor. 1 We affirm the decision of…
2Cases cited3 opinions
- Miller v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1936
- Reilly Oil Co. v. CommissionerUnited States Tax Court · 1949
- Toklan Royalty Corporation v. JonesDistrict Court, W.D. Oklahoma · 1944
3Cited by20 opinions
- Reef Corporation v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Reef CorporationCourt of Appeals for the Fifth Circuit · 1966
- Pebble Springs Distilling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
- Kass v. CommissionerUnited States Tax Court · 1973
- Becher v. CommissionerUnited States Tax Court · 1954
- Murrin v. CommissionerUnited States Tax Court · 1955
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