Legal Opinion

Commissioner of Internal Revenue v. McCann

Court of Appeals for the Second Circuit

Decided December 21, 1944No. 48PublishedCited by 23 opinions

1Opinion of the Court

L. HAND, Circuit Judge.

This appeal (petition to review) is from an order of the Tax Court, expunging a deficiency assessed by the Commissioner against a donor as a gift tax for the year ■1939. The only question involved is the value of the gift. The taxpayer owned more than two-thirds of what were known as “A” shares of stock in a Delaware corporation, known as McCann-Erickson, Inc. These shares had all the voting rights and were cumulatively preferred in dividends up to seven per cent; they were followed by about 15,000 “B” shares, of which the taxpayer gave 2500 to his wife on November 27,…

2Cases cited6 opinions

  1. Helvering v. SalvageSupreme Court of the United States · 1936
  2. Powers v. CommissionerSupreme Court of the United States · 1941
  3. Wilson v. BowersCourt of Appeals for the Second Circuit · 1932
  4. Lomb v. SugdenCourt of Appeals for the Second Circuit · 1936
  5. Kline v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1942

1 more not listed; retrieve them via the Exa API.

3Cited by23 opinions

  1. Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
  2. Speed v. Transamerica CorporationDistrict Court, D. Delaware · 1955
  3. Richardson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
  4. Berzon v. CommissionerUnited States Tax Court · 1975
  5. Estate of True v. CommissionerCourt of Appeals for the Tenth Circuit · 2004

18 more not listed; retrieve them via the Exa API.

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