Liberty Tobacco Company v. Commissioner of Internal Revenue

Third Circuit

Liberty Tobacco Company v. Commissioner of Internal Revenue

214 F.2d 131, 45 A.F.T.R. (P-H) 1710, 1954 U.S. App. LEXIS 3703

CourtCourt of Appeals for the Third Circuit

DecidedJune 30, 1954

Docket11279

StatusPublished

This text of 214 F.2d 131 (Liberty Tobacco Company 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.

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Liberty Tobacco Company v. Commissioner of Internal Revenue, 214 F.2d 131, 45 A.F.T.R. (P-H) 1710, 1954 U.S. App. LEXIS 3703 (3d Cir. 1954).

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Opinion

PER CURIAM.

We have examined carefully the record in this case and have given full consideration to the arguments and the briefs of the parties. No useful purpose would be served by a detailed account of the facts or of the points in controversy. We state, however, that the Tax Court did not err in it's determination of the respective- partners’ proportionate interests in the assets of the partnership, pre-incorporation. The stipulation so heavily relied on by Liberty does not compel a contrary result. We are of the opinion fthat the Tax Court correctly decided all the issues presented. - Accordingly, the decision of the Tax Court will be affirmed..

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PER CURIAM.

We have examined carefully the record in this case and have given full consideration to the arguments and the briefs of the parties. No useful purpose would be served by a detailed account of the facts or of the points in controversy. We state, however, that the Tax Court did not err in it's determination of the respective- partners’ proportionate interests in the assets of the partnership, pre-incorporation. The stipulation so heavily relied on by Liberty does not compel a contrary result. We are of the opinion fthat the Tax Court correctly decided all the issues presented. - Accordingly, the decision of the Tax Court will be affirmed..

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214 F.2d 131, 45 A.F.T.R. (P-H) 1710, 1954 U.S. App. LEXIS 3703, Counsel Stack Legal Research, https://law.counselstack.com/opinion/liberty-tobacco-company-v-commissioner-of-internal-revenue-ca3-1954.

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