International Investment Corp. v. Commissioner of Internal Revenue

Third Circuit

International Investment Corp. v. Commissioner of Internal Revenue

175 F.2d 772, 38 A.F.T.R. (P-H) 124, 1949 U.S. App. LEXIS 3348

CourtCourt of Appeals for the Third Circuit

DecidedJune 20, 1949

Docket9931

StatusPublished

Cited by1 cases

This text of 175 F.2d 772 (International Investment Corp. v. Commissioner of Internal Revenue) 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.

Bluebook

International Investment Corp. v. Commissioner of Internal Revenue, 175 F.2d 772, 38 A.F.T.R. (P-H) 124, 1949 U.S. App. LEXIS 3348 (3d Cir. 1949).

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Opinion

PER CURIAM.

This is a petition to review a decision of the Tax Court that a loss claimed by the petitioner upon the complete liquidation of Portage Water Company, a wholly owned subsidiary, was not recognizable for income tax purposes under Section 112(b) (6) of the Internal Revenue Code, 26 U.S.C.A. § 112(b) (6). The property received by the petitioner upon the liquidation of its subsidiary consisted wholly of cash. Upon the authority of Tri-Lakes S. S. Co. v. Commissioner of Internal Revenue, 6 Cir. 1945, 146 F.2d 970, and for the reasons stated by the Tax Court in its opinion in the present case filed by Judge Kern, 11 T.C. 678, the decision of the Tax Court will be affirmed.

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PER CURIAM.

This is a petition to review a decision of the Tax Court that a loss claimed by the petitioner upon the complete liquidation of Portage Water Company, a wholly owned subsidiary, was not recognizable for income tax purposes under Section 112(b) (6) of the Internal Revenue Code, 26 U.S.C.A. § 112(b) (6). The property received by the petitioner upon the liquidation of its subsidiary consisted wholly of cash. Upon the authority of Tri-Lakes S. S. Co. v. Commissioner of Internal Revenue, 6 Cir. 1945, 146 F.2d 970, and for the reasons stated by the Tax Court in its opinion in the present case filed by Judge Kern, 11 T.C. 678, the decision of the Tax Court will be affirmed.

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Bluebook (online)

175 F.2d 772, 38 A.F.T.R. (P-H) 124, 1949 U.S. App. LEXIS 3348, Counsel Stack Legal Research, https://law.counselstack.com/opinion/international-investment-corp-v-commissioner-of-internal-revenue-ca3-1949.

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