Legal Opinion
Jacobson v. Commissioner
Court of Appeals for the Third Circuit
Decided July 26, 1960No. Nos. 13080-13084PublishedCited by 22 opinions
1Opinion of the Court
HASTIE, Circuit Judge.
The question on these petitions is whether taxpayers were justified in reporting as capital gains rather than ordinary income amounts they realized from the sale of their capital stock of Hudson Towers, Inc., a corporation formed and used for the building of a housing project. The Commissioner contends and the Tax Court has ruled that Hudson Towers, Inc., is a “collapsible corporation” within the meaning of Section 117(m) of the Internal Revenue Code of 1939, as amended by Section 212 of the Revenue Act of 1950, 64 Stat. 906, 26 U.S.C., 1952 ed., § 117(m), and as in…
2Cases cited3 opinions
- Raymond G. Burge and Kathleen E. Burge v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- Arthur Glickman Herman Glickman and Ruth Glickman and Aaron Glickmand and Freda Glickman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- August v. CommissionerCourt of Appeals for the Third Circuit · 1959
3Cited by22 opinions
- Todd Tibbals and Helen A. Tibbals v. The United StatesUnited States Court of Claims · 1966
- United States v. Harold W. Ivey and Mrs. Virginia Ivey, Harold W. Ivey and Mrs. Virginia Ivey v. United StatesCourt of Appeals for the Fifth Circuit · 1961
- Braunstein v. CommissionerCourt of Appeals for the Second Circuit · 1962
- Sproul Realty Co. v. CommissionerUnited States Tax Court · 1962
- Computer Sciences Corp. v. CommissionerUnited States Tax Court · 1974
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