Legal Opinion
Carnahan v. United States
District Court, D. Montana
Decided October 31, 1960No. Civ. 2021PublishedCited by 2 opinions
1Opinion of the Court
JAMESON, District Judge.
Plaintiff taxpayers, husband and wife,, seek recovery of $52,843.96 paid under-protest on August 11, 1958, pursuant to> an assessment of income tax deficiency for the year 1952, with penalties and interest. The question presented is whether the Commissioner of Internal Revenue properly determined that Sarah Carnahan realized taxable gain upon the exchange of old common stock of Mc-Nair Realty Company for new series “B” nonvoting stock within the meaning of Section 112 of the Internal Revenue Code of 1939. 1
The plaintiffs are residents of California, Sarah Carnahan…
2Cases cited15 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Bazley v. CommissionerSupreme Court of the United States · 1947
- Helvering v. SprouseSupreme Court of the United States · 1943
- Fowler v. Crown-Zellerbach CorporationCourt of Appeals for the Ninth Circuit · 1947
- Elko Lamoille Power Co. v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1931
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3Cited by2 opinions
- Estate of Parshelsky v. CommissionerCourt of Appeals for the Second Circuit · 1962
- Estate Of Moses L. Parshelsky, DeceasedCourt of Appeals for the Second Circuit · 1962