Legal Opinion
Hightower v. Commissioner
Court of Appeals for the Ninth Circuit
Decided February 12, 2008No. 06-73838PublishedCited by 1 opinion
1Opinion of the Court
MEMORANDUM **
The stock payment Glenn Hightower received for his share of Green Hills was *647taxable income in 2000 because it was received without restriction as to its disposition and because Hightower had no fixed legal obligation to restore the funds to any other party. See N. Am. Oil Consol. v. Burnet, 286 U.S. 417, 424, 52 S.Ct. 613, 76 L.Ed. 1197 (1932); Hope v. Comm’r, 471 F.2d 738, 741-42 (3d Cir.1973). The possibility that the stock transaction could have later been unwound by a California court does not alter the analysis. See Healy v. Comm’r, 345 U.S. 278, 284, 73 S.Ct. 671, 97 L.Ed.…
2Cases cited8 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- James v. United StatesSupreme Court of the United States · 1961
- Healy v. CommissionerSupreme Court of the United States · 1953
- Karl and Hilda Hope, in Nos. 71-1993, 71-1994 v. Commissioner of Internal Revenue, in No. 71-1995Court of Appeals for the Third Circuit · 1973
- Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1947
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Clinton Deckard v. CommissionerUnited States Tax Court · 2020