Legal Opinion
W & W Fertilizer Corp. v. United States
United States Court of Claims
Decided December 17, 1975No. 17-74PublishedCited by 23 opinions
1Opinion of the CourtLaramore, Senior Judge
This is an action to recover Federal corporate income taxes paid by plaintiff, under protest, for the taxable year ended March 31, 1970. The sole question presented is whether the taxpayer’s prior election to be treated as a “small business corporation” under Subchapter S of the Internal Revenue Code of 19541 terminated when one of its shareholders transferred his stock to a revocable inter vivos trust.2
The relevant facts are as follows: Plaintiff, W&W Fertilizer Corporation (hereinafter referred to as “W&W” or as “taxpayer”), was incorporated under the laws of the State of Florida in 1907.…
2Cases cited20 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Corliss v. BowersSupreme Court of the United States · 1930
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
15 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- William B. Wilson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1977
- Ellis First National Bank of Bradenton v. United StatesUnited States Court of Claims · 1977
- Kesling v. KeslingIndiana Court of Appeals · 2012
- American Nurseryman Publishing Co. v. CommissionerUnited States Tax Court · 1980
- Estate of Lovett v. United StatesUnited States Court of Claims · 1980
18 more not listed; retrieve them via the Exa API.