Legal Opinion

Sam Frank, Jr., and Esther Frank, Willie L. McNatt and Helen C. McNatt v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided September 9, 1963No. 17230_1PublishedCited by 24 opinions

1Opinion of the Court

BLACKMUN, Circuit Judge.

The Commissioner determined deficiencies in the 1956 and 1957 federal income taxes of Sam Frank, Jr. and Willie L. McNatt (and their respective spouses). These deficiencies were attributable to determinations (1) that the taxpayers in acquiring shares of two insurance companies had received compensation and (2) that gains realized on the sale of shares of those corporations and reported as long term capital gains were not entitled to that favorable tax treatment because (a) the taxpayers were dealers in securities and (b) they had not held the shares for more than six…

2Cases cited30 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Helvering v. GowranSupreme Court of the United States · 1937
  4. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  5. United States v. BessSupreme Court of the United States · 1958

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

3Cited by24 opinions

  1. Thomas W. Banks v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  2. Bynum v. CommissionerUnited States Tax Court · 1966
  3. The Municipal Bond Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1965
  4. Flintridge Station Associates v. American Fletcher Mortgage Company and American Fletcher National BankCourt of Appeals for the Seventh Circuit · 1985
  5. United States v. WernentinCourt of Appeals for the Eighth Circuit · 1965

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

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