Legal Opinion

Dougherty v. Commissioner

United States Tax Court

Decided March 12, 1974No. Docket No. 2400-69Published

Held, petitioners' motion to withdraw conditionally their election to have the provisions of sec. 962, I.R.C. 1954, apply with respect to their taxable year 1963 is denied.

1Opinion of the Court

Albert L. and Charlotte K. Dougherty, Petitioners v. Commissioner of Internal Revenue, Respondent

Dougherty v. Commissioner

Docket No. 2400-69

United States Tax Court

61 T.C. 719; 1974 U.S. Tax Ct. LEXIS 145; 61 T.C. No. 76;

March 12, 1974, Filed

Decision will be entered in accordance with respondent's computation.

Held, petitioners' motion to withdraw conditionally their election to have the provisions of sec. 962, I.R.C. 1954, apply with respect to their taxable year 1963 is denied.

Thomas J. Donnelly, Jr., and John A. Hazelwood, for the petitioners.

Robert T. Hollohan, for the respondent.

Tannenwald,…

2Cases cited23 opinions

  1. Pacific National Co. v. WelchSupreme Court of the United States · 1938
  2. Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
  3. Pollack v. CommissionerUnited States Tax Court · 1966
  4. Bayley v. CommissionerUnited States Tax Court · 1960
  5. Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974

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