Legal Opinion
Aaron Kraut v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 31, 1975No. 359--360PublishedCited by 4 opinions
1Opinion of the Court
MULLIGAN, Circuit Judge:
These appeals by taxpayers raise once again the question of the tax consequences under § 1222(3) 1 of the Internal Revenue Code of 1954 of a sale of stock by an ordinary seller to a tax-exempt purchaser, when the sale is financed by the profits of the sold business. See CIR v. Brown, 380 U.S. 563, 85 S.Ct. 1162, 14 L.Ed.2d 75 (1965) (Clay Brown). The transactions involved here preceded the Tax Reform Act of 1969 2 and the decision below was rendered before the opinion of this court in Berenson v. CIR, 507 F.2d 262 (2 Cir. 1974). The question posed is to what extent, if…
2Cases cited11 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Helvering v. TaylorSupreme Court of the United States · 1935
- Commissioner v. BrownSupreme Court of the United States · 1965
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- McSpadden v. CommissionerUnited States Tax Court · 1968
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3Cited by4 opinions
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Kansas City S. R. Co. v. CommissionerUnited States Tax Court · 1981
- Kansas City S. R. Co. v. CommissionerUnited States Tax Court · 1981
- Kovens v. CommissionerUnited States Tax Court · 1983