Legal Opinion
H. Dale Gunther and Marie M. Gunther v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided August 6, 1990No. 89-1872PublishedCited by 17 opinions
1Opinion of the Court
BAUER, Chief Judge.
The Internal Revenue Service appeals from a decision by the United States Tax Court holding that appellees did not owe additional taxes for 1981 despite changes in the corporate structure of two closely-held corporations which they wholly-owned and controlled. In 1981, the appellees reorganized their businesses by exchanging all of their stock in one corporation for stock and debentures from the second corporation. The Internal Revenue Service considered the transaction to be governed by 26 U.S.C. § 304(a) and thus argued that the debentures were taxable as dividends. The…
2Cases cited15 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Reiter v. Sonotone Corp.Supreme Court of the United States · 1979
- Reiter v. Sonotone Corp.Supreme Court of the United States · 1979
- Louis Buddy Yosha v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- United States v. One Parcel of Real Estate Commonly Known as 916 Douglas Avenue, Elgin, Illinois, Appeal of Paul F. Born, Iii, Claimant-AppellantCourt of Appeals for the Seventh Circuit · 1990
10 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Darby v. CommissionerUnited States Tax Court · 1991
- Estate of Ruby Miller Whittle, Deceased, Citizens National Bank of Decatur, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1993
- Estate of Owen v. CommissionerUnited States Tax Court · 1995
- Hurst v. Comm'rUnited States Tax Court · 2005
- Thomas C. Cadwallader and Judy C. Douglas v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1990
12 more not listed; retrieve them via the Exa API.