Legal Opinion

Federal Cement Tile Company v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided December 16, 1964No. 14588_1PublishedCited by 17 opinions

1Opinion of the Court

SWYGERT, Circuit Judge.

This review of a Tax Court decision concerns corporate income tax deficiencies totaling approximately $621,000. The correctness of the decision depends upon an interpretation of the loss carryover provisions under the 1939 Internal Revenue Code, the application of section 24(b) of the 1939 Code, and a determination whether certain “management services” fees constituted ordinary and necessary business expenses. The Tax Court decision is reported at 40 T.C. No. 114 where the facts are related in detail. We shall give only a summary.

Petitioner Federal Cement Tile Company…

2Cases cited6 opinions

  1. Commissioner v. HeiningerSupreme Court of the United States · 1943
  2. Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
  3. McWilliams v. CommissionerSupreme Court of the United States · 1947
  4. Ingle Coal Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1949
  5. J. G. Dudley Company, Incorporated (Formerly Headen Hosiery Mills, Incorporated) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1962

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

3Cited by17 opinions

  1. H. F. Ramsey Co. v. CommissionerUnited States Tax Court · 1965
  2. Clarksdale Rubber Co. v. CommissionerUnited States Tax Court · 1965
  3. Tracinda Corp. v. CommissionerUnited States Tax Court · 1998
  4. Frank Ix & Sons Virginia Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
  5. Fawick Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1965

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

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