Legal Opinion
Commissioner of Internal Revenue v. Grace H. Cunningham, Eugene F. Cunningham and Grace H. Cunningham
Court of Appeals for the Ninth Circuit
Decided July 29, 1958No. 15815PublishedCited by 7 opinions
1Opinion of the Court
ORR, Circuit Judge.
The Tax Court refused to sustain income tax deficiencies assessed by the Commissioner against Grace Cunningham for the year 1946 and, alternatively, against Grace Cunningham and her husband, Eugene F. Cunningham, as a community, for the year 1952. The Commissioner appeals.
Pursuant to an oral agreement, in 1946 the American Manufacturing Company, Inc., a heavy machinery manufacturing concern owned by taxpayers' family and in which Mrs. Cunningham was the major stockholder, erected improvements upon land owned by her at a cost of approximately $20,000. By this same agreement…
2Cases cited2 opinions
- Helvering v. BruunSupreme Court of the United States · 1940
- M. E. Blatt Co. v. United StatesSupreme Court of the United States · 1938
3Cited by7 opinions
- Fieland v. CommissionerUnited States Tax Court · 1980
- Hilldun Corp. v. CommissionerUnited States Tax Court · 1967
- MCGRATH v. COMMISSIONERUnited States Tax Court · 2002
- Cash & Lincoln Fence Co. v. CommissionerUnited States Tax Court · 1982
- Clement v. And Marjorie A. Conole, Petitioners-Appellants-Cross v. Commissioner of Internal Revenue, Respondent-Appellee-CrossCourt of Appeals for the Fifth Circuit · 1973
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