# Associates Inv. Co. v. Commissioner

> United States Tax Court · December 20, 1972 · 59 T.C. 441

URL: https://www.frixlaw.com/law-library/cases/4482157

## Case

- **Full name:** Associates Investment Company, Alleged Transferee of The Protective Life Insurance Company v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** December 20, 1972
- **Citations:** 59 T.C. 441; 59 T.C. No. 42; 1972 U.S. Tax Ct. LEXIS 8
- **Precedential status:** Published
- **Opinion:** Concurrence by Dawson
- **Judges:** Simpson,Dawson
- **Cited by:** 5 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4482157

## Opinion text

DawsoN, J., concurring: I agree with the result in this case for the reasons expressed by Judge Simpson. I was the author of the opinion in Badger Materials, Inc., 40 T.C. 725 (1963), subsequently withdrawn in 40 T.C. 1061 (1963). Justice Frankfurter said in Henslee v. Union Planters Bank, 335 U.S. 595, 600 (1949), “Wisdom too often never comes, and so one ought not to reject it merely because it comes late.” I now believe that the literal interpretation I gave to the statute in Badger Materials was wrong, and I will not compound the error.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4482157. Public record. Not legal advice.