Legal Opinion

Estate of Thoreson v. Commissioner

United States Tax Court

Decided December 10, 1954No. Docket No. 35117PublishedCited by 3 opinions

1Opinion of the Court

OPINION.

Bruce, Judge:

The issue in this case is whether Alfred B. Thoreson received “back pay” in 1946 from the A. O. Jostad Company which would have been paid in 1932, 1933, 1934, and 1935 except for the intervention of an event similar in nature to bankruptcy or receivership within the meaning of sections 107 (d) (1) and 107 (d) (2) (A) (iv), Internal Bevenue Code of 1939.1

Petitioner contends that the financial condition of the A. O. Jostad Company in 1932 through 1935 was an event similar to bankruptcy or receivership.

The parties are in agreement and the record clearly shows that the A. O.…

2Cases cited7 opinions

  1. Kenny v. CommissionerUnited States Tax Court · 1945
  2. Cowan v. Henslee, Collector of Internal Revenue. Klein v. Henslee, Collector of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950
  3. Langer's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1950
  4. Bavis v. CommissionerUnited States Tax Court · 1952
  5. Sedlack v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1953

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

3Cited by3 opinions

  1. Roy R. Brooks and Betty B. Brooks v. United StatesCourt of Appeals for the Fifth Circuit · 1960
  2. Robillard v. CommissionerUnited States Tax Court · 1961
  3. Robillard v. CommissionerUnited States Tax Court · 1961

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