Harold M. Reynolds v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
1Opinion of the Court
DAVID A. NELSON, Circuit Judge.
The question in this case is whether the doctrine of judicial estoppel ought to be applied against the Commissioner of Internal Revenue on the issue of who, as between the petitioner and the petitioner’s former spouse, is to be taxed on a certain capital gain. The gain resulted from the sale, in 1977, of leasehold interests and mineral rights in a coal mine. In 1983 the Commissioner determined that sale proceeds nominally received by petitioner’s wife were attributable to petitioner. Earlier, however, in bankruptcy proceedings involving the wife, the…
2Cases cited18 opinions
- Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984
- Protective Committee for Independent Stockholders of TMT Trailer Ferry, Inc. v. AndersonSupreme Court of the United States · 1968
- Scarano v. Central R. Co. Of New JerseyCourt of Appeals for the Third Circuit · 1953
- William Edwards v. Aetna Life Insurance CompanyCourt of Appeals for the Sixth Circuit · 1982
- Grady Allen v. Zurich Insurance CompanyCourt of Appeals for the Fourth Circuit · 1982
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- Bokum v. CommissionerUnited States Tax Court · 1990
- United States of America v. Stan D. Owens, Van Wert County Sheriff, John G. Spirko, Jr.Court of Appeals for the Sixth Circuit · 1995
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