Legal Opinion

William B. Wilson v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided October 11, 1977No. 75-2775PublishedCited by 28 opinions

1Opinion of the Court

GOLDBERG, Circuit Judge.

Subchapter S of the Internal Revenue Code provides a method for certain electing close corporations to exempt themselves from corporate income taxes. Their income is taxable directly to the shareholders, all of whom must consent to such treatment. The question in this ease is whether William B. Wilson, Inc. validly elected to come within subchapter S. That question in turn depends upon the definition of “shareholder” for purposes of determining who must consent. More particularly, the issue is whether that term extends to an individual who was the record holder of one…

2Cases cited10 opinions

  1. Kean v. CommissionerCourt of Appeals for the Ninth Circuit · 1972
  2. Alfred N. Hoffman and Deli Hoffman v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Reba Martin, Inc.Court of Appeals for the Fifth Circuit · 1968
  3. Rupe Investment Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
  4. Pacific Coast Music Jobbers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1972
  5. Hook v. CommissionerUnited States Tax Court · 1972

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

3Cited by28 opinions

  1. United States v. Albert J. Pirro, Jr., Anthony G. PirroCourt of Appeals for the Second Circuit · 2000
  2. Danenberg v. CommissionerUnited States Tax Court · 1979
  3. Esmark, Inc. v. CommissionerUnited States Tax Court · 1988
  4. Stephen D. Pahl Louise A. Pahl v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
  5. Cabintaxi Corporation, Formerly Known as Automated Transit, Incorporated, and Robert Edler, "Tax Matters Person," v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1995

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

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