Legal Opinion
Patty R. Smith v. United States
Court of Appeals for the Sixth Circuit
Decided May 11, 1972No. 71-1331PublishedCited by 21 opinions
1Opinion of the Court
McCREE, Circuit Judge.
Appellants are taxpayers who appeal from a judgment of the District Court upholding the Commissioner’s determination that lump-sum payments to each of them of their respective interests in their employer’s profit-sharing plan were taxable as ordinary income. The plan was funded by contributions to a trust which was tax-exempt under the provisions of the Internal Revenue Code of 1939 and under section 501(a) of the Internal Revenue Code of 1954, 26 U.S. C. § 501(a). 1 It was adopted by appellants’ employer, Adkins Cargo Express, Inc. (Cargo), when that company acquired…
2Cases cited20 opinions
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- United States v. Ophelia Johnson and Ophelia R. Johnson, as Under the Last Will and Testament of Clifford L. Johnson, DeceasedCourt of Appeals for the Fifth Circuit · 1964
- Miller v. CommissionerUnited States Tax Court · 1954
- Glinske v. CommissionerUnited States Tax Court · 1951
15 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Reinhardt v. CommissionerUnited States Tax Court · 1985
- Rudolph F. Adler Jacquelyn L. Adler v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1996
- Burton v. CommissionerUnited States Tax Court · 1992
- Sarmir v. CommissionerUnited States Tax Court · 1976
- Gegax v. CommissionerUnited States Tax Court · 1979
16 more not listed; retrieve them via the Exa API.