Legal Opinion

John F. Knowlton and Betty F. Knowlton v. Commissioner of Internal Revenue

Court of Appeals for the Eleventh Circuit

Decided June 24, 1986No. 17-13073PublishedCited by 24 opinions

1Opinion of the Court

TUTTLE, Senior Circuit Judge:

No. 85-3842.

Petitioners John F. and Betty W. Knowl-ton, hereinafter “taxpayers,” seek to have this Court reverse the decision of the Tax Court of the United States which affirmed findings by the Commissioner of Internal Revenue of substantial deficiencies in their 1978 taxes.

I. BACKGROUND

Petitioners were shareholders of Dunmo-vin Corporation, a personal holding company. In 1978, Dunmovin was completely liquidated pursuant to Internal Revenue Code § 333. As a part of the liquidation, Mrs. Knowlton, who owned 975 shares of Dunmovin non-voting stock, received…

2Cases cited8 opinions

  1. Commissioner v. BrownSupreme Court of the United States · 1965
  2. United States v. E. I. Du Pont De Nemours & Co.Supreme Court of the United States · 1957
  3. United States v. E. I. Du Pont De Nemours & Co.Supreme Court of the United States · 1961
  4. Klein v. Board of Tax Supervisors of Jefferson Cty.Supreme Court of the United States · 1930
  5. Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971

3 more not listed; retrieve them via the Exa API.

3Cited by24 opinions

  1. Rose v. CommissionerUnited States Tax Court · 1987
  2. Sealy Power, Ltd. v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
  3. Exxon Corp. v. CommissionerUnited States Tax Court · 1994
  4. Johnson v. United StatesUnited States Court of Claims · 1986
  5. David B. Greenberg v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2021

19 more not listed; retrieve them via the Exa API.

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