Legal Opinion
Waterman Steamship Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided September 17, 1970No. 27563PublishedCited by 55 opinions
1Opinion of the Court
WISDOM, Circuit Judge:
This case involves another attempt by a taxpayer to ward off tax blows with paper armor. The issue for decision is whether the declaration and payment, in the form of a promissory note,1 of $2,-799,820 by Pan-Atlantic Steamship Cor-*" poration to its parent, Waterman Steamship Corporation, was a tax-free, inter-*1186company dividend, as the Tax Court concluded? 50 T.C. 650. Or was it part of the purchase price paid to Waterman in a sale by Waterman of the stock of Pan-Atlantic and Gulf Florida Terminal Company to McLean Securities Company, as the Commissioner contends? If the…
2Cases cited29 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
24 more not listed; retrieve them via the Exa API.
3Cited by55 opinions
- Connie Edwards v. Your Credit, Inc.Court of Appeals for the Fifth Circuit · 1998
- E. Keith Owens v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
- Emory K. Crenshaw, as of the Estate of Frances Wood Wilson, Deceased v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Beech Aircraft Corporation v. United StatesCourt of Appeals for the Tenth Circuit · 1986
- Owens v. CommissionerUnited States Tax Court · 1975
50 more not listed; retrieve them via the Exa API.