|
|
Ivan Allen Co. v. United States, 422 U.S. 617 (1975)
Contents:
Show Summary
Hide Summary
General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Ivan Allen Co. v. United States, 422 U.S. 617 (1975)
Ivan Allen Co. v. United States No. 74-22 Argued April 115, 1975 Decided June 26, 1975 422 U.S. 617
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE FIFTH CIRCUIT
Syllabus
In determining the applicability of § 533(a) of the Internal Revenue Code of 1954 -- which provides a rebuttable presumption that a corporation that has accumulated earnings "beyond the reasonable needs of the business" did so with "the purpose to avoid the income tax with respect to shareholders" -- listed and readily marketable securities owned by the corporation and purchased out of its earnings and profits are to be taken into account not at their cost to the corporation, but at their net liquidation value. Pp. 624-635.
493 F.2d 426, affirmed.
BLACKMUN, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, MARSHALL, and REHNQUIST, JJ., joined. POWELL, J., filed a dissenting opinion, in which DOUGLAS and STEWART, JJ., joined, post, p. 635.
Contents:
Chicago: U.S. Supreme Court, "Syllabus," Ivan Allen Co. v. United States, 422 U.S. 617 (1975) in 422 U.S. 617 Original Sources, accessed May 20, 2024, http://www.originalsources.com/Document.aspx?DocID=5712N7A22LSMJ7F.
MLA: U.S. Supreme Court. "Syllabus." Ivan Allen Co. v. United States, 422 U.S. 617 (1975), in 422 U.S. 617, Original Sources. 20 May. 2024. http://www.originalsources.com/Document.aspx?DocID=5712N7A22LSMJ7F.
Harvard: U.S. Supreme Court, 'Syllabus' in Ivan Allen Co. v. United States, 422 U.S. 617 (1975). cited in 1975, 422 U.S. 617. Original Sources, retrieved 20 May 2024, from http://www.originalsources.com/Document.aspx?DocID=5712N7A22LSMJ7F.
|