Legal Opinion

Commissioner v. Kuckenberg

Court of Appeals for the Ninth Circuit

Decided October 11, 1962No. 17538PublishedCited by 33 opinions

1Opinion of the Court

MERRILL, Circuit Judge.

Kuckenberg Construction Company, an Oregon corporation, pursuant to a plan of complete liquidation sold and assigned three construction contracts, the income from which had been fully earned, to an independent purchaser for $327,000.00. The company was on the cash method of accounting. The question presented by this review is whether, under § 337(a) of the Internal Revenue Code of 1954, 26 U.S.C.A. § 337(a),1 nonrecognition attached to the proceeds of this sale. The tax court held for the taxpayers and the commissioner has petitioned this court for review. We here hold…

2Cases cited14 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. Helvering v. HorstSupreme Court of the United States · 1940
  3. Commissioner v. SternSupreme Court of the United States · 1958
  4. United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
  5. Helvering v. EubankSupreme Court of the United States · 1941

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

3Cited by33 opinions

  1. Commissioner of Internal Revenue v. D. B. AndersCourt of Appeals for the Tenth Circuit · 1969
  2. Estate of Munter v. CommissionerUnited States Tax Court · 1975
  3. Verito v. CommissionerUnited States Tax Court · 1965
  4. Anders v. CommissionerUnited States Tax Court · 1967
  5. Schneider v. CommissionerUnited States Tax Court · 1975

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

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