Legal Opinion
Television Industries, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided November 14, 1960No. 10, Docket 26144PublishedCited by 69 opinions
1Opinion of the Court
FRIENDLY, Circuit Judge.
This is a petition by a taxpayer to review a decision of the Tax Court, 32 T.C. 1297, finding petitioner liable as transferee for a deficiency of $77,199.53, together with interest, in the income tax of National Phoenix Industries, Inc., hereafter “Phoenix.” This finding stems from a conclusion that $1,026,285 received by Phoenix from Nedick’s, Inc. on November 15, 1951, and not reported as income, was taxable to Phoenix as a dividend under § 115(g) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 115 (g). The facts, which are not disputed, are set forth at length…
2Cases cited16 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Gray v. PowellSupreme Court of the United States · 1941
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- Commissioner of Internal Revenue v. Ashland Oil & Refining Co.Court of Appeals for the Sixth Circuit · 1938
- Joseph R. Holsey and Eleanor T. Holsey v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
11 more not listed; retrieve them via the Exa API.
3Cited by69 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Yelencsics v. CommissionerUnited States Tax Court · 1980
- Montgomery Coca-Cola Bottling Co. v. United StatesUnited States Court of Claims · 1980
- Edgar S. Idol, Katherine G. Idol, and Speedway Transports, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Charles P. Ballenger, Jr., and Myrtle S. Ballenger v. United StatesCourt of Appeals for the Fourth Circuit · 1962
64 more not listed; retrieve them via the Exa API.