I picked up this posting of a list of Women Lawyers at DOJ in 1937. Dan Ernst, Women Lawyers at the Department of Justice, 1937 (Legal History Blog), here. The actual list is here. The list does not break down the women by division. Wikipedia says that the Tax Division was formed in 1934. See Wikipedia entry here.
At least one on the list -- Helen R. Carloss -- handled tax cases, including in the Supreme Court. I recognized her name and so first did a Google search and then a LEXIS-NEXIS search. I report some of the results below.
Before reporting the results on Helen Carloss, however, I want to say that I don't mean to slight any of the others, particularly those who might have worked on tax cases or for the Tax Division after it was formed. I am just time limited, so any reader who wants to pick one or more names to write a blog entry or a comment on, please do so and let me know.
An ancestry entry is here, which says:
Helen Carloss earned plaudits from Justice William O. Douglas for her skill as an advocate for the government in tax cases from the 1920s to the 1940s.The same entry has the following which is attributed as an article in the Washington Post on March 28, 1934:
Source: The United States Supreme Court: The Pursuit of Justice - by Christopher L. Tomlins, Houghton Mifflin - 2005.
The Washington Post ¦ Wednesday, March 28, 1934 ¦ page 15
Woman Attorney Dashes About the Country Defending Government in Tax Cases
Assistant to Attorney General Handles Much Work on Trains
Helen Carloss Is First Women to Argue Cases Before All U.S. Courts of Appeal; Went From Teaching to Government Work
Escape! That is what Government Work represents to some women. Escape from the dull, colorless life of a small town. A school teacher have up a position in a little Mississippi town to accept an humble clerkship with the Government because she wanted to get away from teaching. She wanted to be where things were happening. Now the former school teacher and clerk is a special assistant to the Attorney General of the United States.
This is the ninth in a series of articles telling of women with interesting Government positions.
By Virginia Lee Warren
THE HONOR OF BEING the first woman to argue cases before all of the United States courts of appeals belongs to Miss Helen R. Carloss, soft-voiced, dark-eyed daughter of
Mississippi. As these courts are scattered throughout the country, Miss Carloss, in the four years she has been special assistant to the Attorney General, has spent considerable time dashing off to San Francisco, New Orleans, Chicago and Atlanta to represent the Government in tax cases. She also apeared before courts of appeals in New York, Boston, Kansas City, Cincinnati, St. Louis, Baltimore, Richmond and Asheville.
"But I spend at least half my time in Washington," explained Miss Carloss yesterday at her office in the Investment Building. "The cases are assigned to me here by the head of
the tax division, Department of Justice. Then I prepare the briefs before I start on my travels."
Lots of Last Minute Work.
But no matter how much time she spends on the briefs, this woman attorney has found there is always last-minute work to be done on the train. She says in spite of her travels she has seen very little of the country?s scenery because all her waking hours on her trips are spent in going over legal papers.
The majority of Miss Carloss' cases are those that have been appealed from Federal district courts or from the board of tax appeals. In most instances, according to the special assistant to the Attorney General, the Government is attempting to collect more taxes than the taxpayer filed on his tax return. She complained this condition results from a difference in the interpretation of the law. Criminal tax cases are not in her province. She is assigned only those that require civil action and are argued entirely on points of law.
My most interesting case?
Miss Carloss studied the question for a moment before she replied, "Well, I believe it was the one I had in New Orleans last year which involved the evaluation of an application for a patent on cracking oil. It is the cracking process that gasoline is extracted from oil. In this particular case we had to determine the value of the patent on the process so the government could estimate the income of the patent holder."
Before she had finished with the case, Miss Carloss knew the complete history of the oil industry. She won her case. By her victory the Government received $500,000 in taxes.
A Habit of Winning Cases.
This woman lawyer has a habit of winning her cases. It has reached the point where opponents usually prepare for her by engaging three or four of the best men lawyers they can get.
In spite of her success as an attorney with the Government, Miss Carloss believes that a woman lawyer has a more interesting life and makes more money if she is engaged in private practice. "Her experiences are more varied and usually more profitable, financially," declared the special assistant to the Attorney General. "But I would advice (sic) the young woman lawyer, when she starts out t build up practice, to have enough money to see her through for at least two years. A man lawyer would probably need only enough money for one year.
Since there is still a little prejudice against women in the legal profession, beginners should be prepared for a slow start. After they have built up practices I think they can go just as far as men attorneys."
This prejudice against women lawyers, where it exists, is invariable on the part of the layman believes Miss Carloss. She declared in every court where she has appeared the men attorneys have treated her with professional respect. "They have never shown me any favors; they have treated me as an equal. That is the way it should be," she added.
Hated Teaching School.
Helen Carloos was born in Yazoo City, Miss., in the house that had belonged to her family for several generations. At the time she entered Mississippi State College for Women there were very few occupations considered suitable for girls from good Southern families Teaching school was the favored one. It was nice, clean, respectable work and paid a fairly good salary. So Helen Carloss became a teacher.
"I hated it. Simply hated it." Her dark eyes snapped as she recalled the unhappy experience. It was while she was looking about for something else to do and she admits she would have done almost anything to get away from teaching that one of her friends received a Government appointment. The little Mississippi town was all excited and saw the young woman off to Washington in great style. That gave Helen Carloss an idea.
She too, would go to Washington and work for the Government. It was 1918 when she same to the Capital.
She began as a clerk in the income tax division of the Internal Revenue Bureau.
Had Stroke of Luck.
"Of course, I had nothing to do with selecting the department in which I would work," she said. ?I was so thrilled to be in Washington that I didn't care what department I was in or what my job wasat first. But after I had been in the income tax division for a few months, I realized there were opportunities for advancement."
Miss Carloss wanted to be ready for those opportunities. She enrolled in the law school of George Washington University and soon after she had received her LL.B. in 1923, she was made technical clerk in the rules and regulations section of the income tax division. "That gave me a chance to apply my knowledge of law. But after I had spent five years as technical clerk I knew I had reached a standstill. Then I had a stroke of luck. One of the women attorneys at the Department of Justics went to Europe. I was appointed to take her place."
The appointment was made in March, 1928. Nine month later Helen Carloss was arguing cases. Two years later she was appointed special assistant to the Attorney General. "And I'm still arguing cases," she smiled.
Picture of Helen Carloss
Under the picture: Born within the stately walls of the old family homestead at Yazoo City, Miss. (above), Miss Helen Carloss gives the lie to the traditional languor of the Southern girl. Today she travels from coast to coast representing the Department of Justice (upper left) in Government tax cases.
Source: http://womenslegalhistory.stanford.edu/articles/CarlossHelen032834.pdfI did a LEXIS-NEXIS search on her name as counsel in cases. It returned 746 entries. 257 of the entries were for Supreme Court cases. I cut and paste the first 50 Supreme Court cases on the search. Most of these were cert petition denials, but DOJ Tax alumni should recognize the names of some prominent tax cases:
1. Estate of Spiegel v. Commissioner, No. 3, SUPREME COURT OF THE UNITED STATES, 335 U.S. 701; 69 S. Ct. 301; 93 L. Ed. 330; 1949 U.S. LEXIS 3048; 49-1 U.S. Tax Cas. (CCH) P10,703; 37 A.F.T.R. (P-H) 459, October 24, 1947, Argued , January 17, 1949, Decided , Reargued October 11-12, 1948.I just picked up 50. There are 257 Supreme Court cases total. And, I found in looking through the list after the first 50 that the Supreme Court earlier identified here as Miss Helen R. Carloss, but the Miss started dropping off with Burton-Sutton
OVERVIEW: Taxability of trust's corpus depended on nature and operative effect of trust transfer and, to be excluded from estate, settlor had to absolutely, unequivocally, and irrevocably part with all title, possession, and enjoyment of transferred property.
CORE TERMS: settlor, beneficiary, reverter, enjoyment, corpus, gift, trust estate, contingent, deceased child, remainder ...
... Attorney General Caudle, Lee A. Jackson and L. W. Post. Helen R. Carloss was also on the brief on the original argument, and ...
2. Nathan v. Commissioner, SUPREME COURT OF THE UNITED STATES, 334 U.S. 843; 68 S. Ct. 1510; 92 L. Ed. 1767; 1948 U.S. LEXIS 2003, June 14, 1948.
... petitioner. George T. Washington, then Acting Solicitor General, Sewall Key, Helen R. Carloss and L. W. Post for respondent. ...
3. Massachusetts v. United States, No. 157, SUPREME COURT OF THE UNITED STATES, 333 U.S. 611; 68 S. Ct. 747; 92 L. Ed. 968; 1948 U.S. LEXIS 2768; 48-1 U.S. Tax Cas. (CCH) P9270; 36 A.F.T.R. (P-H) 622; 1948-1 C.B. 117; 1948 P.H. P72,006, December 10, 1947, Argued , April 19, 1948, Decided
OVERVIEW: The United States could recover from an insolvent debtor's estate federal insurance contribution taxes under Title 8 and unemployment compensation taxes under Title 9 of the Social Security Act because U.S. Rev. Stat. § 3466 required that debts due to the United States should be satisfied first, rather than a debt due to a state.
CORE TERMS: state's claim, assignee, federal governments, Social Security Act, federal claims, insolvency, insolvent, unemployment compensation, federal tax, unemployment ...
... the brief were Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss and Lee A. Jackson.By special leave of Court, Albert ...
4. Commissioner v. Sunnen, No. 227, SUPREME COURT OF THE UNITED STATES, 333 U.S. 591; 68 S. Ct. 715; 92 L. Ed. 898; 1948 U.S. LEXIS 2852; 77 U.S.P.Q. (BNA) 29; 48-1 U.S. Tax Cas. (CCH) P9230; 36 A.F.T.R. (P-H) 611; 1948 P.H. P72,005, December 17, 1947, Argued , April 5, 1948, Decided
OVERVIEW: Collateral estoppel should not have been applied to perpetuate the viewpoint of an assignment because as long as the taxpayer, as the assignor, was the source of the right to receive and enjoy the income, he remained taxable.
CORE TERMS: royalty, collateral estoppel, license, patent, assigned, assignor, res judicata, manufacture, tax year, tax liability ...
... the brief were Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss and L. W. Post.C. Powell Fordyce argued the cause ...
5. Jones v. Liberty Glass Co., No. 71, SUPREME COURT OF THE UNITED STATES, 332 U.S. 524; 68 S. Ct. 229; 92 L. Ed. 142; 1947 U.S. LEXIS 2977; 48-1 U.S. Tax Cas. (CCH) P9113; 36 A.F.T.R. (P-H) 377; 1948-1 C.B. 102; 1947 P.H. P72,008, November 17-18, 1947, Argued , December 22, 1947, Decided
OVERVIEW: A taxpayer's application for a refund of a federal income tax overpayment, which resulted from an IRS auditor's mistake, was time barred. A statute of limitations barred the application regardless of the reason for the overpayment.
CORE TERMS: refund, income tax, overpayment, Revenue Act, tax refund, gift taxes, excess-profits, collected, erroneously, illegally assessed ...
... Solicitor General Perlman, Assistant Attorney General Caudle, Arnold Raum and Helen R. Carloss.Earl Foster argued the cause and filed a brief for ...
6. Kavanagh v. Noble, No. 70, SUPREME COURT OF THE UNITED STATES, 332 U.S. 535; 68 S. Ct. 235; 92 L. Ed. 150; 1947 U.S. LEXIS 2978; 48-1 U.S. Tax Cas. (CCH) P9114; 36 A.F.T.R. (P-H) 383, November 18, 1947, Argued , December 22, 1947, Decided
OVERVIEW: In a taxpayer's action for a refund of income taxes paid, the two-year period of limitations, not the four-year period applicable to other tax claims, applied.
CORE TERMS: refund, period of limitation, collection, deficiency assessment, income tax, overpayment, taxpayer filed, illegal assessment, refund claim, revenue agents ...
... Solicitor General Perlman, Assistant Attorney General Caudle, Arnold Raum and Helen R. Carloss.E. M. Baynes and W. H. Harris argued the cause ...
7. Aviation Club v. Commissioner, SUPREME COURT OF THE UNITED STATES, 332 U.S. 837; 68 S. Ct. 220; 92 L. Ed. 409; 1947 U.S. LEXIS 1565, Dec. 8, 1947.
... for petitioner. Solicitor General Perlman, Assistant Attorney General Caudle and Helen R. Carloss for respondent. ...
8. Canister v. United States, SUPREME COURT OF THE UNITED STATES, 332 U.S. 830; 68 S. Ct. 207; 92 L. Ed. 404; 1947 U.S. LEXIS 1602, Nov. 24, 1947.
... for petitioner. Solicitor General Perlman, Assistant Attorney General Caudle and Helen R. Carloss for the United States. ...
9. Andrus' Trust v. Commissioner, SUPREME COURT OF THE UNITED STATES, 332 U.S. 830; 68 S. Ct. 208; 92 L. Ed. 404; 1947 U.S. LEXIS 1605, Nov. 24, 1947.
... Seidman for petitioners. Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss and Hilbert P. Zarky for respondent. ...
10. Belcher v. Commissioner, SUPREME COURT OF THE UNITED STATES, 332 U.S. 824; 68 S. Ct. 165; 92 L. Ed. 399; 1947 U.S. LEXIS 1631, Nov. 17, 1947.
... Rives for petitioner. Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss and Harry Baum for respondent. ...
11. Stimson Mill Co. v. Commissioner, SUPREME COURT OF THE UNITED STATES, 332 U.S. 824; 68 S. Ct. 165; 92 L. Ed. 400; 1947 U.S. LEXIS 1633, Nov. 17, 1947.
... Klooster for petitioner. Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss, Lee A. Jackson and Carlton Fox for respondent. ...
12. United States v. Landman, SUPREME COURT OF THE UNITED STATES, 332 U.S. 815; 68 S. Ct. 152; 92 L. Ed. 392; 1947 U.S. LEXIS 1651, Nov. 10, 1947.
... the brief in No. 327 were Assistant Attorney General Caudle, Helen R. Carloss and Lee A. Jackson. Huston Thompson and Oscar P. Mast ...
13. Ballester Hermanos v. Buscaglia, SUPREME COURT OF THE UNITED STATES, 332 U.S. 816; 68 S. Ct. 154; 92 L. Ed. 393; 1947 U.S. LEXIS 1656, Nov. 10, 1947.
... Llewellyn for petitioner. Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss and I. Henry Kutz for respondent. ...
14. Humphrey v. Commissioner, SUPREME COURT OF THE UNITED STATES, 332 U.S. 817; 68 S. Ct. 157; 92 L. Ed. 394; 1947 U.S. LEXIS 1659, Nov. 10, 1947.
... Cannon for petitioners. Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss, Lee A. Jackson and Harry Marselli for respondent. ...
15. Humphrey v. Commissioner, SUPREME COURT OF THE UNITED STATES, 332 U.S. 817; 68 S. Ct. 157; 92 L. Ed. 394; 1947 U.S. LEXIS 1660, Nov. 10, 1947.
... Cannon for petitioner. Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss and Maryhelen Wigle for respondent. ...
16. Sanchez v. Commissioner, No. 356, SUPREME COURT OF THE UNITED STATES, 332 U.S. 815; 68 S. Ct. 154; 92 L. Ed. 392; 1947 U.S. LEXIS 3013; 75 U.S.P.Q. (BNA) 365, Nov. 10, 1947.
... Wexler for petitioner. Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss and Hilbert P. Zarky for respondent. ...
17. Steinberg v. United States, SUPREME COURT OF THE UNITED STATES, 332 U.S. 808; 68 S. Ct. 108; 92 L. Ed. 386; 1947 U.S. LEXIS 1712, Oct. 27, 1947.
W. B. Harrell for petitioner. Solicitor General Perlman, Helen R. Carloss, Ellis N. Slack and John H. Mitchell for the United ...
18. Adamston Flat Glass Co. v. Commissioner, SUPREME COURT OF THE UNITED STATES, 332 U.S. 809; 68 S. Ct. 109; 92 L. Ed. 386; 1947 U.S. LEXIS 1713, Oct. 27, 1947.
Charles W. Moxley for petitioner. Solicitor General Perlman, Helen R. Carloss and L. W. Post for respondent. ...
19. Scherf v. Commissioner, SUPREME COURT OF THE UNITED STATES, 332 U.S. 810; 68 S. Ct. 111; 92 L. Ed. 387; 1947 U.S. LEXIS 1717, Oct. 27, 1947.
... Powell for petitioners. Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss and Harry Baum for respondent. ...
20. General Motors Acceptance Corp. v. Higgins, SUPREME COURT OF THE UNITED STATES, 332 U.S. 810; 68 S. Ct. 112; 92 L. Ed. 388; 1947 U.S. LEXIS 1720, Oct. 27, 1947.
... Smith for petitioner. Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss and Morton K. Rothschild for respondent. ...
21. Bramer v. Commissioner, SUPREME COURT OF THE UNITED STATES, 332 U.S. 771; 68 S. Ct. 85; 92 L. Ed. 356; 1947 U.S. LEXIS 1880, Oct. 13, 1947.
... Kaplan and Maurice J. Mahoney for petitioner. Solicitor General Perlman, Helen R. Carloss and L. W. Post for respondent. ...
22. Nelson v. United States, SUPREME COURT OF THE UNITED STATES, 331 U.S. 846; 67 S. Ct. 1731; 91 L. Ed. 1856; 1947 U.S. LEXIS 2095, June 16, 1947.
... A. Littleton for petitioner. Acting Solicitor General Washington, Sewall Key, Helen R. Carloss and H. S. Fessenden for the United States. ...
23. Commissioner v. Munter, No. 674, SUPREME COURT OF THE UNITED STATES, 331 U.S. 210; 67 S. Ct. 1175; 91 L. Ed. 1441; 1947 U.S. LEXIS 2994; 47-1 U.S. Tax Cas. (CCH) P9241; 35 A.F.T.R. (P-H) 963; 1947-1 C.B. 48; 1947 P.H. P72,005, April 10, 1947, Argued , May 5, 1947, Decided
OVERVIEW: Because taxpayers' liability for deficiencies in reporting as income dividends on stock of a reorganized corporation depended on whether the corporation obtained from predecessor companies accumulated earnings and profits sufficient to cover the dividends, remand was required to analyze the new company's history of earnings and distributions.
CORE TERMS: earnings, stockholder, reorganization, stock, predecessor, revenue acts, dividend, distributed, successor, accumulated earnings ...
... on the brief were Acting Solicitor General Washington, Sewall Key, Helen R. Carloss, Stanley M. Silverberg and I. Henry Kutz.Samuel Kaufman argued ...
24. Spiegel v. Commissioner, SUPREME COURT OF THE UNITED STATES, 331 U.S. 798; 67 S. Ct. 1202; 91 L. Ed. 1823; 1947 U.S. LEXIS 2367, April 28, 1947.
... A. Kohn for petitioners. Acting Solicitor General Washington, Sewall Key, Helen R. Carloss, Stanley M. Silverberg and Melva M. Graney for respondent. ...
25. First Nat'l Bank v. Scofield, SUPREME COURT OF THE UNITED STATES, 331 U.S. 806; 67 S. Ct. 1188; 91 L. Ed. 1827; 1947 U.S. LEXIS 2419, April 14, 1947.
... First National Bank, petitioner. Acting Solicitor General Washington, Sewall Key, Helen R. Carloss and Irving I. Axelrad for respondent. ... 26. United States v. Ogilvie Hardware Co., No. 430, SUPREME COURT OF THE UNITED STATES, 330 U.S. 709; 67 S. Ct. 997; 91 L. Ed. 1192; 1947 U.S. LEXIS 2438; 47-1 U.S. Tax Cas. (CCH) P9209; 35 A.F.T.R. (P-H) 768, March 5, 1947, Argued , April 7, 1947, Decided
OVERVIEW: Under the Revenue Act of 1942, a corporate taxpayer was entitled to a refund of undistributed profits tax paid where the taxpayer experienced an accumulated deficit at the tax year's beginning, and state law prevented a dividend payment.
CORE TERMS: deficit, dividend, refund, Revenue Act, undistributed profits, earnings, accumulated earnings, state law, capitalization, stock ...
... Acting Solicitor General Washington, Sewall Key, Stanley M. Silverberg and Helen R. Carloss.Elias Goldstein argued the cause for respondent. With him on ...
27. Jeffries v. Commissioner, SUPREME COURT OF THE UNITED STATES, 330 U.S. 843; 67 S. Ct. 1083; 91 L. Ed. 1289; 1947 U.S. LEXIS 2500, March 31, 1947.
... M. McNutt for petitioner. Acting Solicitor General Washington, Sewall Key, Helen R. Carloss and Helen Goodner for respondent. ...
28. Whitman Pub. Co. v. United States, SUPREME COURT OF THE UNITED STATES, 330 U.S. 826; 67 S. Ct. 864; 91 L. Ed. 1276; 1947 U.S. LEXIS 2605, March 3, 1947.
... Russell Hardy for petitioner.Acting Solicitor General Washington, Sewall Key, Helen R. Carloss and Elizabeth B. Davis for the United States. ...
29. Varnedoe v. Allen, SUPREME COURT OF THE UNITED STATES, 330 U.S. 821; 67 S. Ct. 771; 91 L. Ed. 1272; 1947 U.S. LEXIS 2657, February 17, 1947.
... B. Cody for petitioner. Acting Solicitor General Washington, Sewall Key, Helen R. Carloss and Muriel S. Paul for respondent. ...
30. Rothensies v. Electric Storage Battery Co., No. 48, SUPREME COURT OF THE UNITED STATES, 329 U.S. 296; 67 S. Ct. 271; 91 L. Ed. 296; 1946 U.S. LEXIS 3145; 47-1 U.S. Tax Cas. (CCH) P9106; 35 A.F.T.R. (P-H) 297; 1947-1 C.B. 109, November 15, 18, 1946, Argued , December 16, 1946, Decided
OVERVIEW: Recoupment was not considered to allow one transaction to be offset against another, but only to permit a transaction, which was made subject to a suit by the taxpayer, to be examined in all its aspects, and judged as one transaction as a whole.
CORE TERMS: recoupment, refund, statute of limitations, excise taxes, income tax, recoup, taxable event, beneficiary, tax laws, taxpayer paid ...
... were Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and Lee A. Jackson.Laurence H. Eldredge argued the cause ...
31. Adams v. Commissioner, SUPREME COURT OF THE UNITED STATES, 329 U.S. 695; 67 S. Ct. 62; 91 L. Ed. 607; 1946 U.S. LEXIS 1926, October 14, 1946.
... petitioner. Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and William Robert Koerner for respondent. ...
32. Bazley v. Commissioner, SUPREME COURT OF THE UNITED STATES, 329 U.S. 701; 67 S. Ct. 77; 91 L. Ed. 611; 1946 U.S. LEXIS 1947, October 14, 1946.
... petitioner. Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and Helen Goodner for respondent. ...
33. Lloyd v. Commissioner, SUPREME COURT OF THE UNITED STATES, 329 U.S. 717; 67 S. Ct. 49; 91 L. Ed. 622; 1946 U.S. LEXIS 1966, October 14, 1946.
... petitioner. Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and Morton K. Rothschild for respondent. ...
34. Hedrick v. Commissioner, SUPREME COURT OF THE UNITED STATES, 329 U.S. 719; 67 S. Ct. 53; 91 L. Ed. 623; 1946 U.S. LEXIS 1972, October 14, 1946.
... petitioner. Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and Hilbert P. Zarky for respondent. ...
35. Realty Operators v. Commissioner, SUPREME COURT OF THE UNITED STATES, 329 U.S. 721; 67 S. Ct. 58; 91 L. Ed. 625; 1946 U.S. LEXIS 1980, October 14, 1946.
... petitioners. Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and Maryhelen Wigle for respondent. Briefs were filed by J. ...
36. Meltzer v. Commissioner, SUPREME COURT OF THE UNITED STATES, 329 U.S. 723; 67 S. Ct. 68; 91 L. Ed. 627; 1946 U.S. LEXIS 1987, October 14, 1946.
... petitioners. Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and S. Dee Hanson for respondent. ...
37. Bank of California Nat'l Asso. v. Commissioner, SUPREME COURT OF THE UNITED STATES, 329 U.S. 725; 67 S. Ct. 73; 91 L. Ed. 628; 1946 U.S. LEXIS 1991, October 14, 1946.
... petitioner. Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and William Robert Koerner for respondent. ...
38. Lowry v. Commissioner, SUPREME COURT OF THE UNITED STATES, 329 U.S. 725; 67 S. Ct. 73; 91 L. Ed. 628; 1946 U.S. LEXIS 1992, October 14, 1946.
... petitioner. Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and Harold C. Wilkenfeld for respondent. ...
39. Kirschenbaum v. Commissioner, SUPREME COURT OF THE UNITED STATES, 329 U.S. 726; 67 S. Ct. 75; 91 L. Ed. 628; 1946 U.S. LEXIS 1994, October 14, 1946.
... petitioners. Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and Morton K. Rothschild for respondent. ...
40. Crossett Western Co. v. Commissioner, SUPREME COURT OF THE UNITED STATES, 329 U.S. 729; 67 S. Ct. 84; 91 L. Ed. 631; 1946 U.S. LEXIS 2002, October 14, 1946.
... petitioner. Solicitor General McGrath, Assistant Attorney General McGregor, Sewall Key, Helen R. Carloss and Helen Goodner for respondent. ...
41. Birch Ranch & Oil Co. v. Commissioner, SUPREME COURT OF THE UNITED STATES, 328 U.S. 863; 66 S. Ct. 1368; 90 L. Ed. 1633; 1946 U.S. LEXIS 2210, June 10, 1946.
Walter H. Maloney for petitioner. Solicitor General McGrath, Sewall Key, Helen R. Carloss and Louise Foster for respondent. ...
42. Rohmer v. Commissioner, SUPREME COURT OF THE UNITED STATES, 328 U.S. 862; 66 S. Ct. 1367; 90 L. Ed. 1632; 1946 U.S. LEXIS 3155; 69 U.S.P.Q. (BNA) 631, June 10, 1946.
Watson Washburn for petitioners. Solicitor General McGrath, Sewall Key, Helen R. Carloss and Melva M. Graney for respondent. Briefs were filed as ...
43. A. B. Frank Co. v. United States, SUPREME COURT OF THE UNITED STATES, 328 U.S. 851; 66 S. Ct. 1339; 90 L. Ed. 1624; 1946 U.S. LEXIS 2320, May 27, 1946.
Theodore B. Benson for petitioner. Solicitor General McGrath, Sewall Key, Helen R. Carloss and Elizabeth B. Davis for the United States. ...
44. Los Angeles Soap Co. v. United States, SUPREME COURT OF THE UNITED STATES, 328 U.S. 848; 66 S. Ct. 1120; 90 L. Ed. 1621; 1946 U.S. LEXIS 2367, May 20, 1946.
... A. J. Dockweiler for petitioner. Solicitor General McGrath, Sewall Key, Helen R. Carloss and Norman S. Altman for the United States. ...
45. Pressed Steel Car Co. v. Commissioner, SUPREME COURT OF THE UNITED STATES, 328 U.S. 838; 66 S. Ct. 1013; 90 L. Ed. 1613; 1946 U.S. LEXIS 2444, May 6, 1946.
Earl F. Reed for petitioner. Solicitor General McGrath, Sewall Key, Helen R. Carloss and William Robert Koerner for respondent. ...
46. Upchurch Packing Co. v. United States, SUPREME COURT OF THE UNITED STATES, 327 U.S. 803; 66 S. Ct. 960; 90 L. Ed. 1028; 1946 U.S. LEXIS 2513, April 22, 1946.
... B. Brennan for petitioner. Solicitor General McGrath, Sewall Key and Helen R. Carloss for the United States. ...
47. Smart v. Commissioner, SUPREME COURT OF THE UNITED STATES, 327 U.S. 804; 66 S. Ct. 962; 90 L. Ed. 1028; 1946 U.S. LEXIS 2516, April 22, 1946.
... L. Neidle for petitioner. Solicitor General McGrath, Sewall Key and Helen R. Carloss for respondent. ...
48. Civiletti v. Commissioner, SUPREME COURT OF THE UNITED STATES, 327 U.S. 804; 66 S. Ct. 963; 90 L. Ed. 1029; 1946 U.S. LEXIS 2517, April 22, 1946.
Paul O'Dwyer for petitioner. Solicitor General McGrath, Sewall Key and Helen R. Carloss for respondent. ...
49. Sewell v. Commissioner, SUPREME COURT OF THE UNITED STATES, 327 U.S. 805; 66 S. Ct. 961; 90 L. Ed. 1030; 1946 U.S. LEXIS 2522, April 22, 1946.
Oliver C. Hancock for petitioner. Solicitor General McGrath, Sewall Key, Helen R. Carloss and Hilbert P. Zarky for respondent. ...
50. Burton-Sutton Oil Co. v. Comm'r, No. 361, SUPREME COURT OF THE UNITED STATES, 328 U.S. 25; 66 S. Ct. 861; 90 L. Ed. 1062; 1946 U.S. LEXIS 3021; 46-1 U.S. Tax Cas. (CCH) P9243; 4 A.F.T.R. (P-H) 1017; 34 A.F.T.R. (P-H) 1017; 1946-1 C.B. 237; 162 A.L.R. 827; 1946 P.H. P72,019, March 25, 1946, Argued , April 22, 1946, Decided
OVERVIEW: Taxpayer properly deducted oil royalty payments made to refining company because transfer of rights to taxpayer was not a sale but an assignment of the right to exploit property with reservation in refining company of an economic interest in oil.
CORE TERMS: oil, depletion, royalty, net profits, economic interest, lease, lessor's, assignor, gross income, rent ...
... Liskow.Solicitor General McGrath, Acting Assistant Attorney General Sewall Key, Helen R Carloss and Hilbert P. Zarky submitted on brief for respondent.
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