Legal Opinion
William F. Sullivan and Rosemary C. Sullivan v. United States
Court of Appeals for the Third Circuit
Decided May 7, 1980No. 79-1240PublishedCited by 53 opinions
1Opinion of the Court
OPINION OF THE COURT
ADAMS, Circuit Judge.
This appeal is brought by federal taxpayers 1 to recover $293,904.63 in federal income taxes, plus interest, levied on income gained from a sale of unimproved real estate and the contemporaneous yet separate assignment of a package of agreements to lease premises to be developed on that land. The taxpayers claim that the district court erred in upholding the government’s determination that, for federal income tax purposes, the taxpayers were bound by the form of the transaction which allocated the major portion of the total sale proceeds to the…
2Cases cited15 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Milton R. Psaty, and Martin M. Psaty v. United StatesCourt of Appeals for the Third Circuit · 1971
- Charles W. Balthrope and Mary v. Balthrope v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
10 more not listed; retrieve them via the Exa API.
3Cited by53 opinions
- Coleman v. CommissionerUnited States Tax Court · 1986
- Bernard D. Spector v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
- Anastasato v. CommissionerCourt of Appeals for the Third Circuit · 1986
- Cook v. United StatesUnited States Court of Federal Claims · 2000
- Comdisco, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1985
48 more not listed; retrieve them via the Exa API.