Legal Opinion
Lowe v. United States
District Court, D. Montana
Decided October 15, 1963No. Civ. No. 402PublishedCited by 2 opinions
1Opinion of the Court
JAMESON, District Judge.
This is an action to recover income taxes assessed and paid for the year 1957. The cause is before the court on defendant’s motion for summary judgment.
A deficiency was assessed against each of the plaintiffs for the tax year 1957. The basis of the deficiency was the Government’s contention that a corporation in which plaintiffs owned stock was a “collapsible corporation”. The plaintiffs did not agree. After settlement conference, plaintiffs submitted offers of compromise settlement, and on December 22, 1960, each of the plaintiffs executed a Treasury Form 870-AD. By…
2Cases cited14 opinions
- Guggenheim v. United StatesUnited States Court of Claims · 1948
- Bank of New York v. United StatesCourt of Appeals for the Third Circuit · 1948
- F. R. Daugette, and F. R. Daugette and Mary E. Daugette v. George D. Patterson, District Director of Internal Revenue, for District of AlabamaCourt of Appeals for the Fifth Circuit · 1958
- Bartolomeo Monge v. James G. Smyth, Collector of Internal Revenue for the First District of CaliforniaCourt of Appeals for the First Circuit · 1956
- Cuba Railroad Company v. United StatesDistrict Court, S.D. New York · 1954
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3Cited by2 opinions
- Cooper Agency v. United StatesDistrict Court, D. South Carolina · 1969
- Uinta Livestock Corp. v. United StatesDistrict Court, D. Wyoming · 1964