Legal Opinion
Commissioner of Internal Revenue v. Trustees Common Stock John Wanamaker Philadelphia
Court of Appeals for the Third Circuit
Decided November 29, 1949No. 9994PublishedCited by 33 opinions
1Per curiam
The sole question in this case is whether cash receipts by the taxpayers resulting from the sale by them of stock in a corporation to its wholly owned subsidiary are taxable as dividends under Section 115(g) of the Internal Revenue Code, 26 U.S.C.A. § 115(g). Upon the authority of Mead Corporation v. Commissioner of Internal Revenue, 3 Cir. 1940, 116 F.2d 187, and for the reasons well stated in the opinion filed by Judge Opper for the Tax Court in banc, 11 T.C. 365, we hold that they are not so taxable.
The decision of the Tax Court will be affirmed.
2Cases cited1 opinion
- Mead Corporation v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1940
3Cited by33 opinions
- Gallagher v. CommissionerUnited States Tax Court · 1962
- Trianon Hotel Co. v. CommissionerUnited States Tax Court · 1958
- Union Bankers Ins. Co. v. CommissionerUnited States Tax Court · 1975
- Commissioner of Internal Revenue v. Roger W. PopeCourt of Appeals for the First Circuit · 1957
- Du Pont Testamentary Trust v. CommissionerUnited States Tax Court · 1976
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