Legal Opinion

Coast Carton Co. v. Commissioner

United States Tax Court

Decided May 18, 1948No. Docket Nos. 11221, 11222Published

1. Held, that under the facts in this case, the Coast Carton Co. was not an association taxable as a corporation in 1940 and 1941, but was wholly owned and operated by James L. Norie. 2. Held, that our decision in Coast Carton Co., 3 T. C. 676; affd., 149 Fed.

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1. Held, that under the facts in this case, the Coast Carton Co. was not an association taxable as a corporation in 1940 and 1941, but was wholly owned and operated by James L. Norie. 2. Held, that our decision in Coast Carton Co., 3 T. C. 676; affd., 149 Fed. (2d) 739, does not preclude this Court from reviewing all the facts presented to it in a different taxable year and arriving at a different decision, where material facts are in evidence which were not before the Court in the former case.

1Opinion of the Court

Coast Carton Company, Petitioner, v. Commissioner of Internal Revenue, Respondent. James L. Norie and Sarah May Norie, Petitioners, v. Commissioner of Internal Revenue, Respondent

Coast Carton Co. v. Commissioner

Docket Nos. 11221, 11222

United States Tax Court

10 T.C. 894; 1948 U.S. Tax Ct. LEXIS 185;

May 18, 1948, Promulgated

Decision will be entered according to the stipulation of the parties.

1. Held, that under the facts in this case, the Coast Carton Co. was not an association taxable as a corporation in 1940 and 1941, but was wholly owned and operated by James L. Norie.

2. Held, that our…

Also in this document: Dissent · Disney; Dissent · Opper.

2Cases cited17 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Cromwell v. County of SacSupreme Court of the United States · 1877
  3. Helvering v. CliffordSupreme Court of the United States · 1940
  4. Helvering v. HorstSupreme Court of the United States · 1940
  5. Southern Pacific Railroad v. United StatesSupreme Court of the United States · 1897

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