Legal Opinion
Richard G. Cline and Carole J. Cline v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided September 2, 1994No. 93-2698PublishedCited by 19 opinions
1Opinion of the Court
RIPPLE, Circuit Judge.
Richard G. Cline, a former senior executive of Jewel Companies, Inc. (“Jewel”), disputes the tax treatment accorded certain payments he received at the time of his resignation from Jewel Foods. The Tax Court concluded that these payments were received in connection with the acquisition of Jewel by American Stores Company (“American Stores”) and constituted “excess parachute payments” under 26 U.S.C. § 280G of the Internal Revenue Code. Consequently, the payments were subject to the golden parachute payments excise tax imposed under 26 U.S.C. § 4999. Mr. Cline and his…
2Cases cited8 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- United Slate, Tile and Composition Roofers, Damp and Waterproof Workers Association, Local 307 v. G & M Roofing and Sheet Metal Company, Inc.Court of Appeals for the Sixth Circuit · 1984
- Hammond Lead Products, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1970
- Living Faith, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1991
- James H. Rutter and Marie R. Rutter v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
3 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Anthony W. Cvelbar v. Cbi Illinois IncorporatedCourt of Appeals for the Seventh Circuit · 1997
- James A. Pittman v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1996
- Charles Reynolds and Beatrice Reynolds v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2002
- Steven H. Toushin v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2000
- Warren L. Baker, Jr. And Dorris J. Baker v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2003
14 more not listed; retrieve them via the Exa API.