Legal Opinion
Commissioner of Internal Revenue v. Wilshire Holding Corporation
Court of Appeals for the Ninth Circuit
Decided April 12, 1961No. 16678PublishedCited by 10 opinions
1Opinion of the Court
CHAMBERS, Circuit Judge.
In Wilshire Holding Corporation v. Commissioner, 9 Cir., 262 F.2d 51, we indicated that so-called rental payments (which in Oesterreich v. Commissioner, 9 Cir., 226 F.2d 798, and Commissioner of Internal Revenue v. Wilshire Holding Corp., 9 Cir., 244 F.2d 904, were determined to be installment payments on purchase) might be apportioned between principal and interest. The case was remanded for consideration of this point.
Back again before the Tax Court, the Commissioner ignored in his proposed computation of taxpayer’s federal income *800taxes for the years 1945 and 1946 at…
2Cases cited4 opinions
- Walburga Oesterreich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- United States v. National Wholesalers, a Corporation M-D Parts Manufacturing Company, National Parts Company and Henry MezoriCourt of Appeals for the Ninth Circuit · 1956
- Wilshire Holding Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Commissioner of Internal Revenue v. Wilshire Holding CorporationCourt of Appeals for the Ninth Circuit · 1957
3Cited by10 opinions
- United States v. CornishCourt of Appeals for the Ninth Circuit · 1965
- Murphy Logging Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1967
- Murphy Logging Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1967
- Estate of Walburga Hedrick v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1969
- Estate of Hedrick v. CommissionerUnited States Tax Court · 1969
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