Legal Opinion
Estate of Robert G. Kluener, Donald E. Hathaway, Co-Executor, Charlotte J. Kluener v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided November 10, 1998No. 97-1201PublishedCited by 34 opinions
1Opinion of the CourtSiler, J., joined by Nelson, J.,
WELLFORD, J. (pp. 640-641), delivered a separate opinion concurring in part and dissenting in part.
OPINION
SILER, Circuit Judge.
This cáse involves the tax consequences of a horse sale. The petitioners are the estate of Robert Kluener and Kluener’s • widow, Charlotte (“the taxpayers”). In ' the late 1980’s, Robert Kluener (“Kluener”) .transferred forty-one horses to his closely-held corporation, sold the horses, then transferred the proceeds back to himself tax-free. •, Respondent, the Commissioner of Internal Revenue (“IRS”), concluded that Kluener himself sold the horses. It issued a notice…
2Cases cited22 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Allentown MacK Sales & Service, Inc. v. National Labor Relations BoardSupreme Court of the United States · 1998
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Helvering v. GregoryCourt of Appeals for the Second Circuit · 1934
17 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Long Term Capital Holdings v. United StatesDistrict Court, D. Connecticut · 2004
- International Game Technology, Inc. v. Second Judicial District Court of the State of Nevada Ex Rel. County of WashoeNevada Supreme Court · 2006
- Richardson v. CommissionerCourt of Appeals for the Sixth Circuit · 2007
- Indmar Products Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- United States v. Donald NewellCourt of Appeals for the Seventh Circuit · 2001
29 more not listed; retrieve them via the Exa API.