Legal Opinion

Howard A. Kurzner and C. A. Kurzner v. United States

Court of Appeals for the Fifth Circuit

Decided May 27, 1969No. 26656_1PublishedCited by 32 opinions

1Opinion of the Court

GEWIN, Circuit Judge:

The appellee-taxpayer, Dr. Howard A. Kurzner, 1 2 is a shareholder and an employee of Gregory Orthopedic Associates, P.A. (hereinafter referred to as GOAPA), an entity organized pursuant to Florida’s new Professional Service Corporation Act. 3 He brought suit in the United States District Court for the Southern District of Florida, 286 F.Supp. 839, alleging that the Commissioner of Internal Revenue had assessed and collected from him unlawful and excessive income taxes for the respective taxable years ended August 31 of 1964 and 1965. In accordance with Revenue Procedure…

2Cases cited21 opinions

  1. Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
  2. Bingler v. JohnsonSupreme Court of the United States · 1969
  3. Pollock v. Farmers' Loan & Trust Co.Supreme Court of the United States · 1895
  4. Morrissey v. CommissionerSupreme Court of the United States · 1935
  5. Helvering v. Coleman-Gilbert AssociatesSupreme Court of the United States · 1935

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3Cited by32 opinions

  1. Roubik v. CommissionerUnited States Tax Court · 1969
  2. Washington v. CommissionerUnited States Tax Court · 1981
  3. McA Inc. And Universal City Studios, Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1982
  4. Larson v. CommissionerUnited States Tax Court · 1976
  5. Birt v. St. Mary Mercy Hospital of Gary, Inc.Indiana Court of Appeals · 1977

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