Legal Opinion
Coles W. Raymond, M.D. And Virginia Raymond, His Wife v. United States
Court of Appeals for the Sixth Circuit
Decided March 5, 1975No. 74--1575PublishedCited by 24 opinions
1Opinion of the Court
McCREE, Circuit Judge.
This is an appeal from a directed verdict for the government in a suit brought under 28 U.S.C. § 1346(a)(1) 1 for refund of federal income taxes. The issues require us to decide whether taxpayers were entitled to have the jury consider whether advances made by them to their wholly-owned corporation were loans and not contributions to capital, and, if the advances were loans, whether taxpayers’ dominant motivation in extending them was to protect their trade or business.
During the summer of 1965, Dr. Coles W. Raymond, a specialist in obstetrics and gynecology, developed a…
2Cases cited11 opinions
- Whipple v. CommissionerSupreme Court of the United States · 1963
- United States v. GeneresSupreme Court of the United States · 1972
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Bernard F. Curry and Marvel I. Curry v. United StatesCourt of Appeals for the Fifth Circuit · 1968
- Michael Berkowitz and Harris Kolbert, as Last Directors and Liquidating Trustees of K & B Trail Properties, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1969
6 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Philhall Corporation v. United StatesCourt of Appeals for the Sixth Circuit · 1976
- Indmar Products Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- Official Committee of Unsecured Creditors of SGK Ventures, LLC v. NewKey Group, LLC (In re SGK Ventures, LLC)United States Bankruptcy Court, N.D. Illinois · 2014
- Casco Bank & Trust Co. v. United StatesCourt of Appeals for the First Circuit · 1976
- Sol Lessinger and Edith Lessinger v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1989
19 more not listed; retrieve them via the Exa API.