Legal Opinion
Frank B. Short and Katherine F. Short, and Richard L. Coleman and Betty B. Coleman v. Commission of Interenal Revenue
Court of Appeals for the Fourth Circuit
Decided April 3, 1962No. 8444PublishedCited by 3 opinions
1Opinion of the Court
BOREMAN, Circuit Judge.
We are concerned with two "collapsible corporations” within the meaning of Int.Rev.Code of 1939, § 117(m), 26 U.S. C.A. § 117 (m). Taxpayers contend that certain funds received by them in 1950 should be treated as long-term capital gains. They here petition for review of the Tax Court’s determinations that these funds are taxable as ordinary income. The cases were consolidated on appeal by order of this court. We agree with the Tax Court that the two corporations are collapsible within the meaning of subsection 117(m) (2) (A) and that the distributions to the taxpayers…
2Cases cited8 opinions
- Raymond G. Burge and Kathleen E. Burge v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- R. A. Bryan and Ruby M. Bryan, C. B. McNairy and Rowena A. McNairy W. H. Weaver and Edith H. Weaver v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- C. D. Spangler and Veva C. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Payne v. CommissionerCourt of Appeals for the Fifth Circuit · 1959
- G. A. Heft and Edna S. Heft v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
3 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Jack and Celia Farber v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Benedek v. CommissionerCourt of Appeals for the Second Circuit · 1970
- Louis Benedek and Janet Benedek v. Commissioner of Internal Revenue, Henry Hirsch and Myrtle G. Hirsch v. Commissioner of Internal Revenue, Alexander P. Hirsch and Mary E. Hirsch v. Commissioner of Internal Revenue, Martin H. Benedek and Leonore Benedek v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970