Legal Opinion

Pope & Talbot, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided April 21, 1975No. 73-3043, 73-3076PublishedCited by 9 opinions

1Opinion of the Court

OPINION

Before KILKENNY and SNEED, Circuit Judges, and WOLLENBERG, * District Judge. PER CURIAM:

This case involves an appeal from the Tax Court, 60 T.C. 74 (1973), and is concerned with the interaction of sections 1201(a) and 631(a), Internal Revenue Code of 1954, as applied to a taxpayer who elected to consider his cutting of timber as a sale or exchange pursuant to section 631(a). The taxable years in question are 1966 and 1967.

Under section 631(a) the cutting of timber by a taxpayer who has elected its benefits and who meets the 6 months holding period is treated as capital gain to the…

2Cases cited1 opinion

  1. Pope & Talbot, Inc. v. CommissionerUnited States Tax Court · 1973

3Cited by9 opinions

  1. Pesch v. CommissionerUnited States Tax Court · 1982
  2. Willamette Industries, Inc. v. CommissionerUnited States Tax Court · 1987
  3. Stevenson Co-Ply, Inc. v. CommissionerUnited States Tax Court · 1981
  4. Ellingson Timber Co. v. CommissionerUnited States Tax Court · 1977
  5. Estate of Sidles v. CommissionerUnited States Tax Court · 1976

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