26 U.S.C. § 425
Renumbered § 424]
[renumbered]
Notes of Decisions
Cited in 8
cases, 1938–1993 · leading case: Comptroller of the Treasury v. Crown Central Petroleum Corp.
Comptroller of the Treasury v. Crown Central Petroleum Corp. (1982)
“power to vote, (2) any company the election of a majority of whose directors is controlled in any manner by such bank holding company; or (3) any company with respect to the management or policies of which such bank holding company has the power, directly or indirectly, to…”
Warren H. Schumann and Maria T. Schumann v. Commissioner of Internal Revenue (1988)
“26 U.S.C. § 425 (c). Second, if so, was it a disqualifying disposition under section 422(a)(1) which provides: (a) In general.”
In Re Hillsborough Holdings Corp. (1993)
“The facts which are relevant to the matter under consideration and are without dispute can be summarized as follows: \ The Debtors elected pursuant to 26 U.S.C. § 425 to operate on a fiscal, as distinguished from a calendar year, basis.”
Dorothy E. Brown and Donald Lee Brown and United States National Bank of Oregon, Etc. v. United States (1970)
“26 U.S.C. § 425 (h) (3) (C). 8 . “[A] change, which accelerates the time when the option is first exercisable, or which provides more favorable terms for the payment for the stock purchased under the option, is a modification.”
Brown v. United States (1968)
“26 U.S.C. § 425 (h) (1). Taxpayer was the president of M and M Wood Working Company (M & M).”
Hope v. United States (1985)
“§ 83 and 26 U.S.C. § 425 (h). The Court also finds such an extension of the § 425(h) rules to be entirely unreasonable.”
Wanvig v. United States (1969)
“(That attribution section is now 26 U.S.C. § 425 (d)). All the references hereinafter to statutory-sections are to those existing in 1961.”
Baldwin v. Commissioner of Internal Revenue (1938)
“26 U.S.C.A. § 425 ; and see 31 U.S.C.A. § 192 .”
Annotations are extracted automatically from the opinions in the
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treatment. Dots show Syfertize treatment of the citing case itself.