Legal Opinion
George R. Tollefsen and Margaret A. Tollefsen v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 19, 1970No. 582, Docket 34203PublishedCited by 59 opinions
1Opinion of the Court
MOORE, Circuit Judge:
On this appeal we are asked to review the determination of the Tax Court that the withdrawals by George R. Tollefsen from Tollefsen Manufacturing Corp., the wholly-owned subsidiary of Tollefsen Brothers, Inc., which in turn was owned by Tollefsen and his wife (taxpayers), were taxable dividends and not loans.
The facts were fully developed at an evidentiary proceeding before Judge Rauxn and in the findings that he filed with his opinion on July 24, 1969. 52 T.C. 671 (1969). For present purposes we will recite only those facts needed to present the circumstances in broad…
2Cases cited8 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
- Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. CaldwellCourt of Appeals for the Second Circuit · 1953
- Meyer v. CommissionerUnited States Board of Tax Appeals · 1941
- Regensburg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
3 more not listed; retrieve them via the Exa API.
3Cited by59 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Charles A. Sammons, Individually, and Estate of Rosine S. Sammons, Deceased, Charles A. Sammons, Independent v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
- Rapid Electric Co. v. CommissionerUnited States Tax Court · 1973
- Joseph Lupowitz Sons, Inc. v. CommissionerCourt of Appeals for the Third Circuit · 1974
- Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
54 more not listed; retrieve them via the Exa API.