§

Louisville Prop. Co. v. Comm'r

47 B.T.A. 23 (B.T.A. 1942)
Louisville Prop. Co. v. Comm'r

3 Cited authorities

  1. Riley Co. v. Commissioner

    311 U.S. 55 (1940)   Cited 175 times
    Affirming on alternative ground not raised in the trial court or appellate court, noting that "[w]here the decision below is correct it must be affirmed by the appellate court though the lower tribunal gave a wrong reason for its action"

  2. In re Owl Drug Co.

    21 F. Supp. 907 (D. Nev. 1937)   Cited 18 times

    No. 480. September 8, 1937. E.P. Carville, U.S. Atty., of Reno, Nev. Thatcher Woodburn, of Reno, Nev., and Clarence A. Shuey and Grant H. Wren, both of San Francisco, Cal., for trustee, George K. Edler. YANKWICH, District Judge. The Owl Drug Company, a Nevada corporation, was adjudicated a bankrupt, upon a voluntary petition, on October 10, 1932. On November 2, 1932, George K. Edler was appointed trustee, qualifying on November 28, 1932. He is still so acting. The bankrupt, prior to bankruptcy, operated

  3. Philadelphia Rapid Transit Co. v. United States, (1935)

    10 F. Supp. 591 (Fed. Cl. 1935)   Cited 6 times
    In Philadelphia Rapid Transit Company v. United States, 10 F. Supp. 591, 81 Ct.Cl. 289, cert. denied, 300 U.S. 664, 57 S.Ct. 507, 81 L.Ed. 872, we held that the Commissioner acted illegally and without authority when he applied an overpayment of tax by a corporate lessee as a credit against a tax due from the lessor corporation, notwithstanding a contractual obligation of lessee corporation to pay taxes assessed against the lessor, since lessee was not "the taxpayer" within the meaning of the statute permitting credit of an overpayment against a deficiency.