Legal Opinion
Victor Leff and Mary Leff, Husband and Wife v. Commissioner of Internal Revenue, George Sindeband v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided July 31, 1956No. 23701_1PublishedCited by 18 opinions
1Opinion of the Court
HINCKS, Circuit Judge.
These are petitions to review memorandum decisions of the Tax Court (Dec. 20.715M), reported at 13 T.C.M. 1138, holding taxable as ordinary income to the petitioners in 1949 those portions of the proceeds from sales of petitioners’ partnership interests to the remaining partners which were held to represent their respective shares of salary, interest, and partnership profits for the firm’s fiscal year 1948 until the date of dissolution.
We agree with the Tax Court that the petitioners must pay an ordinary income tax on the sales proceeds of their partnership shares to the…
2Cases cited7 opinions
- Helvering v. SmithCourt of Appeals for the Second Circuit · 1937
- Swiren v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1950
- United States v. SnowCourt of Appeals for the Ninth Circuit · 1955
- Meyer v. United StatesCourt of Appeals for the Seventh Circuit · 1954
- Bruce W. Hulbert v. Commissioner of Internal Revenue, Charles H. Edwards v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1955
2 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- James M. Tunnell, Jr., and Mildred S. Tunnell v. United StatesCourt of Appeals for the Third Circuit · 1958
- Hyman Smith and Lillian Smith v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Morris Smith and Esther SmithCourt of Appeals for the Seventh Circuit · 1964
- Ayrton Metal Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Sherlock v. CommissionerUnited States Tax Court · 1960
- Walter L. Berry and Clover G. Berry v. United StatesCourt of Appeals for the Sixth Circuit · 1959
13 more not listed; retrieve them via the Exa API.