Legal Opinion
Paul Cobb, Former District Director of Internal Revenue v. Callan Court Company, United States of America v. W. H. Chambers and Mrs. Rena C. Chambers
Court of Appeals for the Fifth Circuit
Decided January 29, 1960No. 17648PublishedCited by 17 opinions
1Opinion of the Court
JONES, Circuit Judge.
The controversies here presented arise out of the somewhat complex corporate history of the Atlanta Biltmore Hotel Company, herein usually called the Old Company, and its successor, the Atlanta Biltmore Hotel Corporation, which will be referred to as the New Company. The primary question in the case of Cobb v. Callan Court Company is whether distributions to Callan in 1950 from the New Company in redemption of its preferred stock were in partial liquidation and not subject to Federal income taxation as ordinary income to Callan as is provided by Section 115(c) of the…
2Cases cited12 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Farmers Loan & Trust Co. v. MinnesotaSupreme Court of the United States · 1930
- Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
- Flanagan v. HelveringCourt of Appeals for the D.C. Circuit · 1940
7 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Redwing Carriers, Inc. v. TomlinsonCourt of Appeals for the Fifth Circuit · 1968
- Charles P. Ballenger, Jr., and Myrtle S. Ballenger v. United StatesCourt of Appeals for the Fourth Circuit · 1962
- Isidore Himmel and Estate of Lillian Himmel, Isidore Himmel v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
- Redwing Carriers, Inc. v. TomlinsonCourt of Appeals for the Fifth Circuit · 1968
- Estate of Otis E. Byrd, Jimmie Lou Byrd, Administratrix, Peitioner v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
12 more not listed; retrieve them via the Exa API.