Legal Opinion
Madison Fund, Inc. (Formerly the Pennroad Corporation) v. Commissioner of Internal Revenue (Two Cases)
Court of Appeals for the Third Circuit
Decided August 24, 1966No. 15590_1PublishedCited by 2 opinions
1Opinion of the Court
OPINION OF THE COURT
HASTIE, Circuit Judge.
The petitioning taxpayer, Madison Fund, Inc., — formerly The Pennroad Corporation — is contesting Tax Court decisions, 43 T.C. 215, determining deficiencies in its income tax for the taxable years 1956, 1958 and 1960. The matter in dispute is the computation of gain or loss upon the taxpayer’s sales of securities from time to time between 1952 and I960.1 More specifically, the question is whether the basis of each security thus sold should be reduced and, if so, how much, by reason of the taxpayer’s receipt from the Pennsylvania Railroad in 1947 of…
2Cases cited5 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Collins v. CommissionerUnited States Board of Tax Appeals · 1942
- Commissioner of Internal Revenue v. The Pennroad Corporation and Affiliated CompaniesCourt of Appeals for the Third Circuit · 1955
- Madison Fund, Inc. v. CommissionerUnited States Tax Court · 1964
- Winslow Engineering Company, Appellant-Petitioner v. Leroy Smith, an Individual, Doing Business as Rol Pak Co., Appellee-RespondentCourt of Appeals for the Ninth Circuit · 1955
3Cited by2 opinions
- Elward v. United StatesDistrict Court, N.D. Illinois · 1976
- Madison Fund, Inc. (Formerly the Pennroad Corporation) v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Third Circuit · 1966