Legal Opinion
Reynolds v. Boos
Court of Appeals for the Eighth Circuit
Decided March 16, 1951No. 14108PublishedCited by 23 opinions
1Opinion of the Court
JOHNSEN, Circuit Judge.
Under section 22(b) of the Internal Revenue Code, 26 U.S.C.A. § 22(b), property acquired by gift “shall not be included in gross income and shall be exempt from taxation” of income.
Did the cancellation of some rental indebtedness by a lessor represent a gift in the present situation or did it constitute taxable income to the lessee?
The question arises in a suit against a Collector of Internal Revenue for refund of the income taxes paid by the lessee on cancellations of $8,232 made by the lessor in each of the years 1940 and 1941. The district court granted the refunds,…
2Cases cited8 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Bartels v. BirminghamSupreme Court of the United States · 1947
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Hart-Bartlett-Sturtevant Grain Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1950
- Helvering v. Jane Holding CorporationCourt of Appeals for the Eighth Circuit · 1940
3 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Putoma Corp. v. CommissionerUnited States Tax Court · 1976
- Putoma Corp., Successor by Merger of Pro-Mac Company, Petitioners- Cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1979
- William J. Sullivan and Georgia K. Sullivan v. United StatesCourt of Appeals for the Eighth Circuit · 1966
- Commissioner of Internal Revenue v. D. B. AndersCourt of Appeals for the Tenth Circuit · 1969
- Eleanor A. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
18 more not listed; retrieve them via the Exa API.