Legal Opinion
Shores Realty Company, Inc. v. United States
Court of Appeals for the Fifth Circuit
Decided October 24, 1972No. 71-2198PublishedCited by 8 opinions
1Opinion of the Court
SIMPSON, Circuit Judge:
Disposition of this appeal requires that we determine the validity of Treasury Regulations § 1.1371-1 (g), as amended, 1 interpreting the “one class of stock” criterion embodied in Section 1371(a) (4), Title 26, United States Code. 2 We expressly reserved decision as to this point m Brennan v. O’Donnell, 5 Cir. 1970, 426 F.2d 218. The “one class of stock” criterion must be satisfied in order for a corporate taxpayer to qualify for favorable tax treatment as a “small business corporation” under Subchapter S of the Internal Revenue Code of 1954, as amended. 3 In this…
2Cases cited13 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Montclair, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1963
- Laurie W. Tomlinson, District Director of Internal Revenue for the District of Florida v. The 1661 CorporationCourt of Appeals for the Fifth Circuit · 1967
- Bernard F. Curry and Marvel I. Curry v. United StatesCourt of Appeals for the Fifth Circuit · 1968
- Gamman v. CommissionerUnited States Tax Court · 1966
8 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Brutsche v. CommissionerUnited States Tax Court · 1976
- Amory Cotton Oil Company, Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1972
- Portage Plastics Company, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1973
- Johnson v. United StatesDistrict Court, E.D. Kentucky · 1974
- Raymond J. Paige and Patricia C. Paige, His Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1978
3 more not listed; retrieve them via the Exa API.