INGLE COAL CORP.

v.

UNITED STATES

Citator

Cited By

• Rapisardi v. United Fruit Co., 441 F.2d 1308 (2d Cir. 1971)
  …since this is a non-jury case the federal rules should be liberally applied when doubts arise as to the admissibility of evidence,” United States v. E. Regensburg & Sons, 124 F.Supp. 687, 693 (SDNY 1954), aff’d 221 F. 2d 336 (2 Cir.), cert. denied, 350 U.S. 842, 76 S.Ct. 83, 100 L.Ed. 751 (1955); and because there is less likelihood that the trier of fact will be confused by irrelevant or immaterial testimony or inflamed by prejudicial remarks, the better course would have been for the court to receive the…
• Griffin & Co. Inc. v. The United States, 389 F.2d 802 (Ct. Cl. 1968)
  …oices were issued in the name of GI, but tax consequences are based upon the substance of transactions, and not upon the forms in which they are clothed. Ingle Coal Corp. v. United States, 127 F.Supp. 573, 579, 131 Ct.Cl. 121, 129 (1955), cert. den. 350 U.S. 842, 76 S.Ct. 82, 100 L.Ed. 751 (1955); Juniper Investment Co. v. United States, 338 F. 2d 356, 259-360, 168 Ct.Cl. 160, 167-168 (1964); Shaw Construction Co. v. Commissioner of Internal Revenue, 323 F. 2d 316, 320 (9th Cir. 1963). The evidence does in…
• Juniper Inv. Co. v. The United States, 338 F.2d 356 (Ct. Cl. 1964)
  …the completed affair should be disregarded for tax purposes, and that substance and reality should prevail over form and sham.” Ingle Coal Corp. v. United States, 127 F.Supp. 573, 578-579, 131 Ct.Cl. 121, 129 (1955) and cases there cited; cert. den. 350 U.S. 842, 76 S.Ct. 82, 100 L.Ed. 751. Here it is apparent that Juniper, a closely held personal holding company, did not engage in the transaction in question on its own behalf, but rather acted as an alter ego on behalf of its two controlling stockholders…