Commissioner of Internal Revenue v. Trustees Common Stock John Wanamaker Philadelphia

COMMISSIONER OF INTERNAL REVENUE v. TRUSTEES COMMON STOCK JOHN WANAMAKER PHILADELPHIA Et Al.

Comm'r of Internal Revenue v. Trs. Common Stock John Wanamaker Philadelphia, 178 F.2d 10 (3d Cir. 1949)

Court: Court of Appeals for the Third Circuit · U.S. Courts of Appeals
Decided: November 29, 1949
Docket: No. 9994
Judges: Maris, McLaughlin, Kalodner
Citations: 178 F.2d 1038 A.F.T.R. (P-H) 10141949 U.S. App. LEXIS 4286

Opinion — Per Curiam

PER 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.

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No later court has written an explanatory parenthetical about this case yet.

Cited by 21 cases

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Relies on it most ⓘ

Webb v. Commissioner67 T.C. 293 (Tax Ct. 1976)
Insilco Corp. v. Commissioner73 T.C. 589 (Tax Ct. 1979)
Bhada v. Commissioner89 T.C. No. 67
Cramer v. Commissioner20 T.C. 679 (Tax Ct. 1953)
Gallagher v. Commissioner39 T.C. 144 (Tax Ct. 1962)
Trianon Hotel Co. v. Commissioner30 T.C. 156 (Tax Ct. 1958)

Most recent

United States v. Devore, Marla A.No. 02-4222 (7th Cir. Feb. 9, 2004)
Merrill Lynch & Co., Inc. & Subsidiaries v. Commissioner120 T.C. No. 3
Merrill Lynch & Co. v. Comm'r120 T.C. No. 3
Edward J. And Janice W. Caamano v. Commissioner of Internal Revenue879 F.2d 156 (5th Cir. 1989)
Bhada v. Commissioner89 T.C. No. 67
Insilco Corp. v. Commissioner73 T.C. 589 (Tax Ct. 1979)

Citing references are not a citator: they show that a later opinion cites this case, not whether it followed, distinguished, or overruled it. Check negative history before relying on this case.

Authorities cited 1

Depth	Case	Cited by
	Mead Corp. v. Comm'r of Internal Rev., 116 F.2d 187 (3d Cir. 1940)	9

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