Legal Opinion
United States v. Charles G. Eidson, Jr.
Court of Appeals for the Fifth Circuit
Decided November 30, 1962No. 19414_1PublishedCited by 57 opinions
1Opinion of the Court
TUTTLE, Chief Judge.
This appeal by the United States from a judgment entered by the District Court without a jury presents the question whether amounts received by the taxpayers in consideration for the assignment by them of their rights under a management contract which they had with an insurance company are taxable as ordinary income or as capital gains. The appel-lees contend, and the District Court found, that the assignment by the taxpayers in return for a payment by the assignee of $170,000 constituted a sale or exchange of a capital asset.
The essential facts are not in dispute.…
2Cases cited11 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
6 more not listed; retrieve them via the Exa API.
3Cited by57 opinions
- Fritz Thompson and Dora M. Thompson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1963
- Pridemark, Inc. v. CommissionerUnited States Tax Court · 1964
- Commissioner of Internal Revenue v. D. B. AndersCourt of Appeals for the Tenth Circuit · 1969
- Bisbee-Baldwin Corporation v. Laurie E. Tomlinson, District Director of Internal Revenue for the District of FloridaCourt of Appeals for the Fifth Circuit · 1963
- United States v. Dresser Industries, Inc.Court of Appeals for the Fifth Circuit · 1963
52 more not listed; retrieve them via the Exa API.