Legal Opinion
Ayrton Metal Company, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided February 1, 1962No. 26903_1PublishedCited by 25 opinions
1Opinion of the Court
MEDINA, Circuit Judge.
The sole questions in the case are whether two payments of $26,000 and $40,000, or parts thereof, constitute capital gains realized by the taxpayer or, as held below, ordinary income. The decision of the Tax Court is reported at 34 T.C. 464. Our jurisdiction is properly invoked under Section 7482 of the Internal Revenue Code of 1954, 26 U.S.C.A. § 7482.
Respondent argues in substance that the transactions involved are complex, that the findings depend upon the demeanor and credibility of witnesses, and that the case involves “no substantial questions of law,” but only…
2Cases cited23 opinions
- Meinhard v. SalmonNew York Court of Appeals · 1928
- Burnet v. LoganSupreme Court of the United States · 1931
- Hort v. CommissionerSupreme Court of the United States · 1941
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957
18 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
- Bisbee-Baldwin Corporation v. Laurie E. Tomlinson, District Director of Internal Revenue for the District of FloridaCourt of Appeals for the Fifth Circuit · 1963
- Nelson Weaver Realty Company, and Nelson Weaver Mortgage Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
- Christine L. Pounds as Independent of the Estate of Horace E. Pounds and Christine L. Pounds v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Estate of Stahl v. Comm'rUnited States Tax Court · 1969
20 more not listed; retrieve them via the Exa API.