In this bankruptcy case, the trustee of Gould Mfg. Co. petitioned to reduce delinquent property tax assessments for 1930-1933 on the ground that they greatly exceeded the actual value of the land and buildings, and sought a determination by the bankruptcy court of the correct tax amounts owed after a sale free of liens. The city and county objected to the court's jurisdiction to revise the assessments. The court held that it lacked authority under section 64a of the Bankruptcy Act to review or reduce state tax assessments based on excessiveness, as that provision permits challenges only to the legality of taxes, not their factual valuation. It reasoned that federal bankruptcy courts must respect the plenary power of state taxing authorities over assessment matters and that the evidence presented failed to establish any illegality. The court therefore reversed the referee and directed payment of the full tax claims.
The case involved a petition by the Milwaukee car ferry company under the federal limitation of liability statute following a vessel disaster, with disputed issues of whether the petitioner qualified as the vessel's owner and whether any fault was within its privity or knowledge. The court held that the petitioner was entitled to limit its liability, finding that it had established the requisite ownership interest or analogous legal relationship to the ferry despite an executory 1928 sale agreement to Grand Trunk Western Railroad Company that remained pending Interstate Commerce Commission approval. The reasoning centered on the broad statutory definition of 'owner,' which encompasses various substantial legal interests that could support liability claims, the executory nature of the transfer making title and control effectively retained by the petitioner at the time of the loss, and evidence that the disaster's causes were not within the petitioner's privity or knowledge.
This case involves a challenge by Buick Motor Company, a Michigan corporation licensed to do business in Wisconsin as a subsidiary of General Motors, to a Wisconsin tax assessment on income derived from its sales activities in the state. The company argued it was liable only for tax on the $2,500 annual net profit specified in its contract with General Motors for selling vehicles, and that prior tax assessments accepting this figure created an estoppel against further taxation. The court dismissed the suit, holding that the company was subject to tax on all income from business transacted in Wisconsin regardless of the contract terms, that the state could correct prior erroneous assessments based on incomplete facts or legal principles, and that no estoppel arose from earlier under-taxation. The decision noted a possible adjustment for an allowable personal property offset but otherwise upheld the assessment authority.
The case involved a wife suing the internal revenue collector to recover taxes paid after she and her husband initially filed separate 1925 income tax returns based on erroneous advice from a deputy collector regarding the basis for calculating a stock sale loss. They later filed a joint amended return before the March 15, 1926 deadline, claiming the loss that eliminated their tax liability, but the collector rejected it. The court overruled the demurrer to the complaint, holding that the complaint stated a valid claim. The reasoning was that the Revenue Act of 1926 permits a choice between separate or joint returns, and this election is not irrevocable if corrected within the statutory filing period, as the law does not intend to bind taxpayers to mistakes made under misadvice before the deadline expires.
The case involved the U.S. government's effort to cancel a naturalization certificate granted to the defendant, a married woman, by a state court. The federal court examined whether the certificate was illegally procured due to the defendant's failure to demonstrate a bona fide intention to reside permanently in the United States, as required by naturalization statutes, noting her testimony showed a plan to return to Germany after a temporary stay. The court concluded that her actions constituted only a temporary sojourn to satisfy residency rules rather than genuine permanent allegiance, and that this defect could not be overcome by the state court's contrary resolution. It held that the statutory requirements for naturalization, including continuous intent tied to renunciation of prior allegiance, were not met, leading to cancellation of the certificate.