green
Positive treatment
4.1 score
Treatment trajectory · 1935 → 2026 · click a year to view as-of
1935
1980
2026
Top citers, strongest first. 3 distinct citers.
How cited ↗
discussed
Cited "see"
Batchelor-Robjohns v. United States
See Michael v. Comm’r, 75 F.2d 966 , 969 (2d Cir.1935) (rejecting taxpayers’ argument “that in one proceeding there must be determined the liability of the petitioner for his own' taxes and his liability ... for the taxes of all other taxpayers” because such a rule “would involve great difficulty in its administration and would practically render valueless the provision of the law which grants a longer period in which to assert the liability of a transferee of assets”). 10 We reach the same outcome under the rights and duties test.
discussed
Cited "see"
Anne (Sandy) Batchelor-Robjohns v. United States
See Michael v. Comm’r, 75 F.2d 966 , 969 (2d Cir.1935) (rejecting taxpayers’ argument “that in one proceeding there must be determined the liability of the petitioner for his own taxes and his liability ... for the taxes of all other taxpayers” because such a rule “would involve great difficulty in its administration and would practically *1287 render valueless the provision of the law which grants a longer period in which to assert the liability of a transferee of assets”). 10 We reach the same outcome under the rights and duties test.
discussed
Cited "see"
S-K Liquidating Co. v. Commissioner
(2×)
See Edward Michael, 22 B.T.A. 639 (1931), affd. per curiam 75 F. 2d 966 (2d Cir. 1935), cert. denied 296 U.S. 579 (1935), where we concluded that the taxpayer’s earlier transferee liability for 1922, sustained by the Board of Tax Appeals, did not preclude the issuance of a notice of deficiency for the taxpayer’s direct liability for 1922 for taxes on income he had earned.
Retrieving the full opinion text from the archive…
MICHAEL et al.
v.
COMMISSIONER OF INTERNAL REVENUE.
v.
COMMISSIONER OF INTERNAL REVENUE.
224.
Court of Appeals for the Second Circuit.
Mar 4, 1935.
L. Hand, Swan, and Chase, Circuit Judges.
Cited by 1 opinion | Published
[*967] [*968] [*969] [*970] S. Wallace Dempsey, of Washington, D. C. (Thomas Dowd, of Salamanca, N. Y., of counsel), for appellants.
Frank J. Wideman, Asst. Atty. Gen., and Sewall Key, John MacC. Hudson, and Ellis N. Slack, Sp. Assts. to Atty. Gen., for appellee.
Before L. HAND, SWAN, and CHASE, Circuit Judges.
PER CURIAM.
Decision affirmed on opinion below.