Legal Opinion
Malone & Hyde, Inc. v. United States
Court of Appeals for the Sixth Circuit
Decided January 20, 1978No. 76-1681PublishedCited by 10 opinions
1Opinion of the Court
PHILLIPS, Chief Judge.
Malone & Hyde, Inc. (hereinafter taxpayer), the plaintiff-appellee, brought an action to recover income taxes alleged to have been assessed erroneously for the fiscal years 1964-66. The district court entered judgment in favor of taxpayer for $392,-212.68. The Government appeals.
The disputed assessments principally concerned an April 1964 transaction in which taxpayer contracted to purchase the assets of Ragland-Potter & Company, Inc. and the six Cooper-Martin Companies for approximately $12,000,000.1 Although the exact amount is in dispute, approximately $3,000,-000 of…
2Cases cited4 opinions
- Copperhead Coal Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1959
- George D. Patterson, District Director of Internal Revenue, Birmingham, Alabama v. Pizitz, Inc., Successor to Louis Pizitz Dry Goods CompanyCourt of Appeals for the Fifth Circuit · 1966
- Commissioner of Internal Revenue v. Chatsworth Stations, Inc.Court of Appeals for the Second Circuit · 1960
- Akron National Bank and Trust Company v. United StatesCourt of Appeals for the Sixth Circuit · 1975
3Cited by10 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Record Wide Distributors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1982
- Diversified Energy, Inc.,plaintiff-Appellant/cross-Appellee v. Tennessee Valley Authority, Defendant-Appellee/cross-AppellantCourt of Appeals for the Sixth Circuit · 2000
- Edison Homes, Inc., Formerly Ardmor, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990
- CORE Special Purpose Fund v. CommissionerUnited States Tax Court · 1985
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