Legal Opinion

Commissioner v. Samuel Bell & Sons

Court of Appeals for the Third Circuit

Decided September 20, 1933No. Nos. 5056-5059PublishedCited by 1 opinion

1Opinion of the Court

DAVIS, Circuit Judge.

The Commissioner of Internal Revenue contends that the Board of Tax Appeals erred in determining that the respondent Samuel Bell & Sons was affiliated with six other corporations during the years, 1924, 1926, and 1927, within the meaning of section 240 (c) of the Revenue Acts of 1924 and 1926 (26 USCA § 993 and note) which provides in part: “For the purpose of this section two or more domestic corporations shall he deemed to he affiliated * * * if at least 95 per centum of the voting stock of two or more corporations is owned by the same interests.”

During the taxable…

2Cases cited5 opinions

  1. Permutit Co. v. Graver Corp.Supreme Court of the United States · 1931
  2. Handy & Harman v. BurnetSupreme Court of the United States · 1931
  3. Burnet v. J. Rogers Flannery & Co.Supreme Court of the United States · 1932
  4. Flannery Bolt Co. v. CommissionerCourt of Appeals for the Third Circuit · 1931
  5. Pokorny Realty Co. v. United StatesUnited States Court of Claims · 1932

3Cited by1 opinion

  1. Crossett Western Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1934

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