[DOWNLOAD] "Estate of Leonard E. Whitlock v. Commissioner of Internal Revenue" by United States Court of Appeals for the Tenth Circuit " eBook PDF Kindle ePub Free

eBook details

Title: Estate of Leonard E. Whitlock v. Commissioner of Internal Revenue
Author : United States Court of Appeals for the Tenth Circuit
Release Date : January 22, 1974
Genre: Law,Books,Professional & Technical,
Pages : * pages
Size : 75 KB

Description

SETH, Circuit Judge. This is an appeal and cross-appeal which concern the taxation of stockholders of a controlled foreign corporation, which was also a foreign personal holding company. The issue centers on the question whether increases in earnings invested in United States property (section 951(a) (1) (B), Int. Rev. Code of 1954) by Whitlock Oil Services, Inc. should be included in taxpayers' gross income. The Commissioner assessed deficiencies based on increases in such earnings so invested. The Tax Court held that the increases should not be included by reason of section 951(d). The opinion of the Tax Court, 59 T.C. 490, and the dissenting opinion, were filed on December 29, 1972.