Legal Opinion

Jones, Collector of Internal Revenue v. Kyle

Court of Appeals for the Tenth Circuit

Decided August 13, 1951No. 4222PublishedCited by 27 opinions

1Opinion of the Court

BRATTON, Circuit Judge.

During the year 1945, O. A. Kyle, hereinafter referred to as the taxpayer, was employed in Saudi Arabia. He included in hi9 income tax return for that year income derived from such employment and paid the tax thereon. A claim for refund was seasonably filed. No action was taken on the claim within six months after the date of its filing, and the taxpayer instituted this action against the Collector of Internal Revenue to recover the amount of the tax paid. The basis of the action was that the income was exempt from tax under section 116(a) of the Internal Revenue Code,…

2Cases cited6 opinions

  1. Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
  2. Cook v. TaitSupreme Court of the United States · 1924
  3. Downs v. COMMISSIONER OF INTERNAL REVENUE.Court of Appeals for the Ninth Circuit · 1948
  4. Swenson v. ThomasCourt of Appeals for the Fifth Circuit · 1947
  5. Myers v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950

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

3Cited by27 opinions

  1. Glenn Weible and Patricia Weible v. United StatesCourt of Appeals for the Ninth Circuit · 1957
  2. Eric N. Umbach v. Commissioner of Internal Revenue, Joseph D. Specking v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 2004
  3. Howard J. Sochurek v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
  4. Nelson v. CommissionerUnited States Tax Court · 1958
  5. Umbach v. CommissionerCourt of Appeals for the Tenth Circuit · 2003

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

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