Legal Opinion

Nat Holt and Blanche Holt, Husband and Wife v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided May 4, 1962No. 17515 and 17516PublishedCited by 55 opinions

1Opinion of the Court

HAMLIN, Circuit Judge.

Petitioners, Nat Holt and Blanche Holt, husband and wife, reported certain income for the years 1953, 1954 and 1955 which they treated as capital gain. The Commissioner of Internal Revenue treating the income as ordinary income assessed deficiencies for taxes due in those years. A petition for redetermination of deficiencies was filed with the Tax Court and the Tax Court upheld the contentions of the Commissioner that the income was to be taxed as ordinary income rather than as capital gain. We have jurisdiction of the petition to review the decision of the Tax Court…

2Cases cited6 opinions

  1. Helvering v. HorstSupreme Court of the United States · 1940
  2. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  3. Hort v. CommissionerSupreme Court of the United States · 1941
  4. Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
  5. Marc D. Leh and L. Waive Leh v. Commissioner of Internal Revenue, David E. Brown and Christobel H. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958

1 more not listed; retrieve them via the Exa API.

3Cited by55 opinions

  1. Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
  2. Luna v. CommissionerUnited States Tax Court · 1964
  3. Diamond v. CommissionerUnited States Tax Court · 1971
  4. Christine L. Pounds as Independent of the Estate of Horace E. Pounds and Christine L. Pounds v. United StatesCourt of Appeals for the Fifth Circuit · 1967
  5. Kingsbury v. CommissionerUnited States Tax Court · 1976

50 more not listed; retrieve them via the Exa API.

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