Legal Opinion
AD Saenger, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided June 8, 1936No. 8023PublishedCited by 28 opinions
1Opinion of the Court
SIBLEY, Circuit Judge.
The Commissioner, affirmed by the Board of Tax Appeals, assessed on the 1929 income of thé taxpayer, A. D. Saenger, Inc., the 50 per cent, extra tax imposed by section 104 of the Revenue Act of 1928 (26 U.S.C.A. § 104 note) on corporations formed or availed of for the purpose of preventing the imposition of surtax on their shareholders. A. D. Saenger and J. H. Saenger were brothers who on March 1, 1927, sold all their assets and business to a corporation, A. & J., Inc., for equal parts of its capital stock of $1,500,000. In February, 1929, that corporation declared a…
2Cases cited4 opinions
- Avery v. CommissionerSupreme Court of the United States · 1934
- United Business Corporation v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1933
- Loose v. United StatesCourt of Appeals for the Eighth Circuit · 1934
- Adler v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Fifth Circuit · 1935
3Cited by28 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Commissioner of Internal Revenue v. Cecil B. De Mille Productions, Inc.Court of Appeals for the Ninth Circuit · 1937
- RL Blaffer & Co. v. Commissioner of Internal Rev.Court of Appeals for the Fifth Circuit · 1939
- A. G. Attebury Et Ux. v. United StatesCourt of Appeals for the Fifth Circuit · 1970
- Frelbro Corp. v. CommissionerUnited States Tax Court · 1961
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