C. Pardee Works v. Duffy

Third Circuit

C. Pardee Works v. Duffy

66 F.2d 1011, 12 A.F.T.R. (P-H) 1337, 1933 U.S. App. LEXIS 2860, 12 A.F.T.R. (RIA) 1337

CourtCourt of Appeals for the Third Circuit

DecidedAugust 21, 1933

DocketNo. 5063

StatusPublished

This text of 66 F.2d 1011 (C. Pardee Works v. Duffy) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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C. Pardee Works v. Duffy, 66 F.2d 1011, 12 A.F.T.R. (P-H) 1337, 1933 U.S. App. LEXIS 2860, 12 A.F.T.R. (RIA) 1337 (3d Cir. 1933).

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Opinion

PER QURIAM.

In the court below (4 F. Supp. 649) the taxpayer sued the internal revenue collector to recover taxes alleged to have been illegally collected. By stipulation, the case was tried by the judge, who found for defendant. Whereupon the taxpayer took this appeal.

The questions involved concern the much-vexed subject of individual and consolidated returns, and the opinion of the judge discusses at length all phases of the ease. His conclusion was: “Finding the fact, as I do, that substantially all the stock of the corporations filing consolidated return, was not owned by the same interests, and applying the law, as hereinbefore stated, as laid down in the case of Handy & Harman v. Burnet [284 U. S. 136, 52 S. Ct. 51, 76 L. Ed. 207], supra, the result is a verdict in favor of the defendant, and judgment may be entered accordingly.”

As we agree with Judge Avis’ reasoning and conclusions, we avoid needless repetition by affirming the ease on his opinion.

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PER QURIAM.

In the court below (4 F. Supp. 649) the taxpayer sued the internal revenue collector to recover taxes alleged to have been illegally collected. By stipulation, the case was tried by the judge, who found for defendant. Whereupon the taxpayer took this appeal.

The questions involved concern the much-vexed subject of individual and consolidated returns, and the opinion of the judge discusses at length all phases of the ease. His conclusion was: “Finding the fact, as I do, that substantially all the stock of the corporations filing consolidated return, was not owned by the same interests, and applying the law, as hereinbefore stated, as laid down in the case of Handy & Harman v. Burnet [284 U. S. 136, 52 S. Ct. 51, 76 L. Ed. 207], supra, the result is a verdict in favor of the defendant, and judgment may be entered accordingly.”

As we agree with Judge Avis’ reasoning and conclusions, we avoid needless repetition by affirming the ease on his opinion.

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66 F.2d 1011, 12 A.F.T.R. (P-H) 1337, 1933 U.S. App. LEXIS 2860, 12 A.F.T.R. (RIA) 1337, Counsel Stack Legal Research, https://law.counselstack.com/opinion/c-pardee-works-v-duffy-ca3-1933.

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