# Seiberling Rubber Co. v. Commissioner

> Court of Appeals for the Sixth Circuit · May 8, 1934 · 70 F.2d 651

URL: https://www.frixlaw.com/law-library/cases/6859014

## Case

- **Full name:** SEIBERLING RUBBER CO. v. COMMISSIONER OF INTERNAL REVENUE
- **Court:** Court of Appeals for the Sixth Circuit
- **Decided:** May 8, 1934
- **Citations:** 70 F.2d 651; 13 A.F.T.R. (P-H) 1049; 1934 U.S. Tax Cas. (CCH) 9286; 13 A.F.T.R. (RIA) 1049; 1934 U.S. App. LEXIS 4251
- **Precedential status:** Published
- **Opinion:** Dissent by Taylor
- **Judges:** Moorman, Taylor
- **Cited by:** 3 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/6859014

## Opinion text

TAYLOR, District Judge
(dissenting).
I dissent from the result reached in this case because I believe petitioner should be given an opportunity to set up inter-company transactions which would reduce its apparent taxable income. It seems to me the disregarding of inter-company transactions by the taxpayer upon the idea that the affiliates would be treated as a unit by the Commissioner and later the Board of Tax Appeals has caused an inequitable result. The ease should, in my opinion, be reopened so that the tax returns may be made to reflect all inter-company transactions, particularly those now" reflected by the books of the affiliates, which would reduce the apparent income of petitioner.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/6859014. Public record. Not legal advice.