Legal Opinion
Walter F. Vorbleski and Florence Vorbleski v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided December 1, 1978No. 78-1154PublishedCited by 32 opinions
1Opinion of the Court
OPINION OF THE COURT
JAMES HUNTER, III, Circuit Judge:
Section 483 of the Internal Revenue Code of 1954 is a general provision which treats as interest a certain part of “any payment” due more than six months after, and which is made on account of, the sale or exchange of property. In Fox v. United States, 510 F.2d 1330 (3d Cir. 1975), this Court held that section 483, despite its seemingly long reach, nevertheless does not apply to deferred payments made in satisfaction of a divorce property settlement because Congress intended the tax treatment of such payments to be governed exclusively by…
2Cases cited13 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- Groman v. CommissionerSupreme Court of the United States · 1937
- King Enterprises, Inc. v. The United StatesUnited States Court of Claims · 1969
8 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Zuanich v. CommissionerUnited States Tax Court · 1981
- Gammill v. CommissionerUnited States Tax Court · 1980
- Anderson v. Comm'rUnited States Tax Court · 2004
- Rand v. Comm'rUnited States Tax Court · 2013
- Mayer v. Development Corp. of AmericaDistrict Court, D. New Jersey · 1981
27 more not listed; retrieve them via the Exa API.