Danielson v. Commissioner
United States Tax Court
Pursuant to the opinion and mandate in Commissioner v. Danielson, 378 F. 2d 771 (C.A. 3, 1967), and further evidence adduced, held, on the facts, that petitioners were not fraudulently induced by Thrift to sign noncompetition agreements in conjunction with the sale of their stock in Butler Loan. Thus, petitioners are bound by the agreements, and the amounts of consideration received therefor are taxable as ordinary income.
1Opinion of the Court
Dawson, Judge:
These cases are now before the Court on remand from the U.S. Court of Appeals for the Third Circuit pursuant to mandate issued on November 7,1967. The cases were originally heard by this Court on November 17 and 18,1964, and decisions were entered in favor of petitioners on September 22, 1965, in accordance with an opinion filed on July 12,1965, which is reported in 44 T.C. 549. Upon petitions for review filed by the Commissioner in the U.S. Court of Appeals for the Third Circuit, the cases were argued before a three-member panel on September 16, 1966. A rehearing before the…
2Cases cited17 opinions
- Griffith v. United Air Lines, Inc.Supreme Court of Pennsylvania · 1964
- Perry O. Hooper, as Trustee in Bankruptcy of Consolidated American Industries, Inc. v. Mountain States Securities CorporationCourt of Appeals for the Fifth Circuit · 1960
- John B. Janigan v. Frederick B. TaylorCourt of Appeals for the First Circuit · 1965
- Kardon v. National Gypsum Co.District Court, E.D. Pennsylvania · 1946
- Danielson v. CommissionerUnited States Tax Court · 1965
12 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Russo v. CommissionerUnited States Tax Court · 1977
- Dodson v. CommissionerUnited States Tax Court · 1969
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Danielson v. CommissionerUnited States Tax Court · 1968
2 more not listed; retrieve them via the Exa API.