Legal Opinion

R. Neal Bright, Etc. v. United States

Court of Appeals for the Fifth Circuit

Decided February 27, 1991No. 90-1453PublishedCited by 5 opinions

1Per curiam

Plaintiff-Appellant R. Neal Bright, the executor of the estate of Elizabeth R. Cornell, appeals the district court’s grant of summary judgment and entry of judgment in favor of Defendant-Appellee, the United States. 1 The district court held that for income tax purposes the check that Cornell’s employee received on December 27, 1985, constituted the receipt of cash or a cash equivalent by Bright on that date. We affirm.

OPERABLE FACTS

In 1970 Ms. Cornell entered into a trust agreement whereby the Elizabeth R. Cornell Trust was created for her benefit. The trust is a “grantor trust” for federal…

2Cases cited9 opinions

  1. Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
  2. Kahler v. Comm'rUnited States Tax Court · 1952
  3. Cowden v. CommissionerCourt of Appeals for the Fifth Circuit · 1961
  4. Lavery v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1946
  5. H. N. Watson, Jr., and Wife, Shirley Watson v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1980

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3Cited by5 opinions

  1. Horace R. Walter Donna L. Walter v. United StatesCourt of Appeals for the Eighth Circuit · 1998
  2. Fromson v. United StatesUnited States Court of Federal Claims · 1994
  3. Rosser v. Comm'rUnited States Tax Court · 2010
  4. Horace R. Walter v. United StatesCourt of Appeals for the Eighth Circuit · 1998
  5. Morgan v. Comm'rUnited States Tax Court · 2010

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