Legal Opinion

Samuel S. Broughton and Loretta T. Broughton v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided June 25, 1964No. 15324PublishedCited by 19 opinions

1Opinion of the Court

FRANK W. WILSON, District Judge.

This is an appeal from the decision of the Tax Court. The appellants, Samuel S. Broughton and Loretta T. Broughton, husband and wife, filed joint federal income tax returns for the years 1954 and 1955. The taxpayers reported in these returns certain income from the sale of separately owned real estate as long term capital gains. They also deducted certain expenses claimed by the husband to be entertainment and travel expense. The Commissioner of Internal Revenue made a determination that the real estate sold by each party in each year here involved was held by…

2Cases cited4 opinions

  1. United States v. United States Gypsum Co.Supreme Court of the United States · 1948
  2. Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
  3. Raymond Bauschard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1960
  4. J. Stewart Mathews and Viola I. Mathews v. Commissioner of Internal Revenue, J. Stewart Mathews v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1963

3Cited by19 opinions

  1. Douglas Goldman and Evelyn K. Goldman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1967
  2. The Municipal Bond Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1965
  3. Philhall Corporation v. United StatesCourt of Appeals for the Sixth Circuit · 1976
  4. Francis E. Gartrell and Mabel L. Gartrell v. United StatesCourt of Appeals for the Sixth Circuit · 1980
  5. Guardian Indus. Corp. v. CommissionerUnited States Tax Court · 1991

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