Legal Opinion
Elsie F. Greentree v. United States
Court of Appeals for the Fourth Circuit
Decided November 19, 1964No. 9516PublishedCited by 6 opinions
1Opinion of the Court
THOMSEN, District Judge.
The government appeals from an adverse judgment after a non-jury trial in an action brought under 28 U.S.C.A. § 1346(a) (1) to recover income taxes paid pursuant to a deficiency assessment. The appeal presents the question how payments made by a corporation over a period of four years to the widow of its deceased president should be treated in her returns: whether as non-taxable gifts, as taxable income to her in the nature of compensation, or as dividends on the stock of the corporation, of which 16% was owned by her and 84% by her two sons.
The district judge found…
2Cases cited9 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Ruth T. Lengsfield, Coralie Mayer Lengsfield and Blanche L. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Eva L. Gaugler, on Behalf of Herself and as Under the Last Will and Testament of Raymond C. Gaugler, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1963
- Mildred W. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Estate of Martin Kuntz, Sr., Deceased, Isabelle M. Kuntz, and Isabelle M. Kuntz, Individually, Surviving Wife v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1962
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- United States v. Andrew TsanasCourt of Appeals for the Second Circuit · 1978
- Estate of Sydney J. Carter, Deceased (A/k/a Sydney J. Canter) v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1971
- Falk v. United StatesDistrict Court, C.D. California · 1967
- Meyer v. United StatesDistrict Court, S.D. California · 1965
- Abdella v. CommissionerUnited States Tax Court · 1983
1 more not listed; retrieve them via the Exa API.