Legal Opinion

J.H. Harris, and William J. Martin v. United States

Court of Appeals for the Fifth Circuit

Decided June 7, 1990No. 89-3024PublishedCited by 32 opinions

1Opinion of the Court

GARWOOD, Circuit Judge:

In this federal income tax refund suit, plaintiffs-appellants, J.H. Harris (Harris) and William J. Martin (Martin), collectively Taxpayers, appeal the district court’s summary judgment in favor of defendant-appel-lee, the United States (Government). We affirm.

Facts and Proceedings Below

In June 1982, Taxpayers contracted with Trans-Lux New Orleans Corporation to purchase for $665,585 cash a New Orleans pornographic theater that they intended to convert into a wedding hall. The Taxpayers’ obligations under the contract were conditioned on their being able to secure from a…

2Cases cited15 opinions

  1. Higgins v. SmithSupreme Court of the United States · 1940
  2. Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
  3. Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
  4. Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
  5. Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945

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

3Cited by32 opinions

  1. Hitchins v. CommissionerUnited States Tax Court · 1994
  2. Rebecca Jo Reser v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1997
  3. Southgate Master Fund, L.L.C. Ex Rel. Montgomery Capital Advisors, LLC v. United StatesCourt of Appeals for the Fifth Circuit · 2011
  4. Spencer v. CommissionerUnited States Tax Court · 1998
  5. Uri v. CommissionerCourt of Appeals for the Tenth Circuit · 1991

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

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