Legal Opinion

Occidental Loan Co. v. United States

District Court, S.D. California

Decided November 13, 1964No. 63-1055PublishedCited by 3 opinions

1Opinion of the Court

BYRNE, District Judge.

On September 5, 1963, Occidental Loan Company, plaintiff, having complied with all conditions precedent, brought this action against the United States of America, defendant, for the recovery of federal income taxes, which plaintiff asserts were illegally assessed and collected. Jurisdiction of this Court is founded upon: 26 U.S.C. § 7422 and 28 U.S.C. § 1346(a) d).

The dispute arises out of the following facts, which are stipulated to by the parties.

On October 31, 1958, plaintiff acquired all of the assets of two of its wholly-owned subsidiaries, when they were completely…

2Cases cited13 opinions

  1. United States v. LudeySupreme Court of the United States · 1927
  2. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
  3. Hertz Corp. v. United StatesSupreme Court of the United States · 1960
  4. Weir Long Leaf Lumber Co. v. CommissionerUnited States Tax Court · 1947
  5. Bertrand W. Cohn v. United States of America, William R. Kent v. United States of America, Louise C. Kent v. United StatesCourt of Appeals for the Sixth Circuit · 1958

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3Cited by3 opinions

  1. Fribourg Navigation Co. v. CommissionerSupreme Court of the United States · 1966
  2. Fribourg Navigation Co. v. CommissionerSupreme Court of the United States · 1966
  3. Seas Shipping Co. v. CommissionerUnited States Tax Court · 1965

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