green
Positive treatment
2.6 score
Treatment trajectory · 1951 → 2026 · click a year to view as-of
1951
1988
2026
Top citers, strongest first. 5 distinct citers.
How cited ↗
discussed
Cited "see"
Bauer v. Commissioner
We have previously expressed the application of this general legal principle to the very issue which we now confront, and we have said that: The formal characterization as loans on the part of the controlling *679 stockholders may be a relevant factor but it should not be permitted to obscure and true substance of the transaction. [Footnote omitted.] Dobkin v. Commissioner, 15 T.C. 31 , 33 (1950) , affd. per curiam 192 F.2d 392 (2d Cir. 1951) ; see Schnitzer v. Commissioner, 13 T.C. 43 (1949) , affd. per curiam, 183 F.2d 70 (9th Cir. 1950) , cert. denied, 340 U.S. 911 (1951) .
discussed
Cited "see"
Nelson v. Commissioner
See Sam Schnitzer, 13 T.C. 43 , affd. 183 Fed. (2d) 70 , certiorari denied 340 U.S. 911 , where we said: "Bookkeeping, form, and the parties' expressions of intent or character, the expectation of repayment, the relation of advances to stockholdings, and the adequacy of the corporate capital previously invested are among circumstances properly to be considered, for the parties' formal designations of the advances are not conclusive, * * * but must yield to 'facts which even indirectly may give rise to inferences contradicting' them. * * *" See also Mattiessen v. Commissioner, 194 Fed. (2d) 659…
cited
Cited "see"
Cochran v. Commissioner
See Sam Schnitzer, 13 T.C. 43 , 60 , affd. per curiam (C.A. 9) 183 Fed. (2d) 70 , certiorari denied 340 U.S. 911 .
discussed
Cited "see, e.g."
Federal Trade Commission v. Cinderella Career and Finishing Schools, Inc.
(2×)
See also SEC v. Harrison, 80 F.Supp. 226, 229 (D.D.C.1948), appeal dismissed 87 U.S.App.D.C. 232 , 184 F.2d 691 (1950), vacated 340 U.S. 908 , 71 S.Ct. 290 , 95 L.Ed. 656 (1951) 15 Cross, The Peoples' Right to Know 197-247 (1953) The so-called 'Freedom of Information Act,' Pub.L. 89-487, 80 Stat. 250 (1966), effective July 4, 1967, as incorporated by Pub.L. 90-23, 81 Stat. 54 (1967) into 5 U.S.C. 552, while not bearing directly on the issue presented in this case, evidences a clear congressional purpose to open the information possessed by federal administrative agencies to the general public …
cited
Cited "see, e.g."
Morris Schnitzer v. Commissioner of Internal Revenue
See also Sam Schnitzer v. Commissioner, 1949, 13 T.C. 43 , affirmed per curiam by this Court, 183 F.2d 70 , certiorari denied, 340 U.S. 911 , 71 S.Ct. 291 , 95 L.Ed. 658 .
Retrieving the full opinion text from the archive…
First National Bank of Mobile
v.
Commissioner of Internal Revenue
v.
Commissioner of Internal Revenue
No. 342.
Supreme Court of the United States.
Jan 2, 1951.
Geo. E. H. Goodner and Scott P. Crampton for petitioner. Solicitor General Perlman for respondent.
Published
C. A. 5th Cir. Certiorari denied.