Legal Opinion

Stahl v. Commissioner

Court of Appeals for the Seventh Circuit

Decided April 9, 1971No. Nos. 18240, 18241, 18398 and 18399PublishedCited by 2 opinions

1Opinion of the Court

SWYGERT, Chief Judge.

These consolidated cases are appeals and cross-appeals from decisions of the Tax Court1 and the District Court for the Northern District of Illinois 2 which *326essentially relate to the federal income tax consequences of the same transaction. The issues raised are whether payments received by a taxpayer in retirement of notes issued to him by his wholly-owned corporation should be accorded capital gain treatment where the notes were issued in payment for the sale to the corporation by the taxpayer of (1) patents, (2) patent applications, as to which notices of allowance or…

2Cases cited2 opinions

  1. Burnet v. LoganSupreme Court of the United States · 1931
  2. Estate of Stahl v. Comm'rUnited States Tax Court · 1969

3Cited by2 opinions

  1. Estate of William F. Stahl, Deceased, Marion B. Stahl, and Marion B. Stahl, Individually, and Cross-Appellants v. Commissioner of Internal Revenue, and Cross-Appellee. Marion B. Stahl, Individually and as of the Estate of William F. Stahl, Deceased, and Cross-Appellant v. United States of America, and Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1971
  2. Lan Jen Chu and Grace Y. P. Chu v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1973

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