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Commissioner Vs. Phipps
Cites for this judgment
- US Supreme Court
- Mar 14, 1949
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U.S. 410 (1949) U.S. Supreme Court Commissioner v. PhippsSearch
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U.S. 410 (1949) Commissioner v. PhippsSearch
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Revenue Act of 1936, and constituted ordinary income. Pp. 336 U. S. 411 -421. 1. The rule of Commissioner v. SansomeSearch
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the necessity to prevent escape of earnings and profits from taxation. Pp. 336 U. S. 414 -417. 2. Harter v. HelveringSearch
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and the subsidiaries had an aggregate net deficit. The issue now before us is whether the rule of Commissioner v. SansomeSearch
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the recipients as dividends. The rule has been held to include liquidations of a subsidiary by its parent. Robinette v. CommissionerSearch
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of an alleged conflict of the decision below with that of the Court of Appeals for the Ninth Circuit in Cranson v. UnitedSearch
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States, 146 F.2d 871. Commissioner v. SansomeSearch
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In Commissioner v. MunterSearch
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U.S. at 331 U. S. 214 -215. See Murchison's Estate v. CommissionerSearch
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Putnam v. UnitedSearch
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of earnings and profits from taxation. The decision of the Court of Appeals for the Second Circuit in Harter v. HelveringSearch
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long been a commonplace of tax law that similar Page 336 U. S. 421 divergences often occur. See Commissioner v. WheelerSearch
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United States v. KauffmannSearch
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Murchison's Estate v. CommissionerSearch
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Harter v. HelveringSearch
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Georday Enterprises, Ltd. v. CommissionerSearch
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Reed Drug Co. v. CommissionerSearch
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Robinette v. CommissionerSearch
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States, 149 F.2d 721. See also Coudon v. TaitSearch
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Murchison's Estate v. CommissionerSearch
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Baker v. CommissionerSearch
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Barnes v. UnitedSearch
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to be distributed to its own stockholders by the transferor corporation in a tax-free reorganization. Commissioner v. MunterSearch
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U.S. Supreme Court Commissioner v. PhippsSearch
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of Commissioner v. SansomeSearch
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Cranson v. UnitedSearch
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Commissioner v. SansomeSearch
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See Murchison's Estate v. CommissionerSearch
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See Commissioner v. WheelerSearch
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Coudon v. TaitSearch
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