Legal Opinion
Ferdinand Cinelli and Sarah M. Cinelli v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided September 5, 1974No. 74-1090PublishedCited by 18 opinions
1Opinion of the Court
CELEBREZZE, Circuit Judge.
This case presents a single question of substantial significance to international commerce and United States taxation of its citizens’ foreign income. That question is the proper means of giving foreign currency a United States dollar value when a foreign government’s official rate of monetary exchange differs from the “free market” or “commercial” rate. Specifically, the issue is the proper measure of U.S. dollar value of real property priced in Italian lire on May 1, 1942. At that time Italy’s official exchange rate was 19.1 lire to the dollar, whereas the free…
2Cases cited21 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. TaylorSupreme Court of the United States · 1935
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Barr v. United StatesSupreme Court of the United States · 1945
- Cook v. TaitSupreme Court of the United States · 1924
16 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Estate of Petschek v. CommissionerUnited States Tax Court · 1983
- George v. CommissionerCourt of Appeals for the Fifth Circuit · 1988
- Ternovsky v. CommissionerUnited States Tax Court · 1976
- Comprehensive Designers International, Ltd. v. CommissionerUnited States Tax Court · 1976
- Durovic v. CommissionerUnited States Tax Court · 1975
13 more not listed; retrieve them via the Exa API.