Spermacet Whaling & Shipping Co. v. Commissioner
United States Tax Court
Upon the entire record, it is held that petitioner, during the taxable year ended April 30, 1948, was not a "resident * * * foreign corporation engaged in trade or business within the United States" as that phrase is used in section 231 (b) of the Internal Revenue Code of 1939, as amended, and that it is therefore not taxable as provided in sections 14 (c) (1) and 15 of the 1939 Code.
1Opinion of the Court
Spermacet Whaling & Shipping Co. S/A, Petitioner, v. Commissioner of Internal Revenue, Respondent
Spermacet Whaling & Shipping Co. v. Commissioner
Docket No. 54931
United States Tax Court
30 T.C. 618; 1958 U.S. Tax Ct. LEXIS 162;
June 13, 1958, Filed
Decision will be entered for the petitioner.
Upon the entire record, it is held that petitioner, during the taxable year ended April 30, 1948, was not a "resident * * * foreign corporation engaged in trade or business within the United States" as that phrase is used in section 231 (b) of the Internal Revenue Code of 1939, as amended, and that it is…
Also in this document: Dissent.
2Cases cited13 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Corliss v. BowersSupreme Court of the United States · 1930
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Griffiths v. CommissionerSupreme Court of the United States · 1939
8 more not listed; retrieve them via the Exa API.