Legal Opinion
White v. Fitzpatrick, Collector of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 10, 1951No. 66, Docket 22068PublishedCited by 39 opinions
1Opinion of the Court
CLARK, Circuit Judge.
Involved in this appeal is the recurring problem of tax savings claimed as a consequence of a transfer of property from husband to wife with resulting lease or license, back. Here neither the Commissioner of Internal Revenue nor the district court has accepted the taxpayer’s view of the transactions ; and he now appeals from the judgment against him in his action for a refund of the deficiency assessed against him by the Commissioner upon his income and victory taxes for the years 1941, 1943, and 1944.
The following are the facts of the case as stipulated by the parties…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
16 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Furman v. CommissionerUnited States Tax Court · 1966
- Felix v. CommissionerUnited States Tax Court · 1954
- Van Zandt v. CommissionerUnited States Tax Court · 1963
- Stearns Magnetic Mfg. Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Stearns (Two Cases)Court of Appeals for the Seventh Circuit · 1954
- C. P. And Helen Brooke v. United StatesCourt of Appeals for the Ninth Circuit · 1972
34 more not listed; retrieve them via the Exa API.