Legal Opinion
William D. Little v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided February 11, 1997No. 95-70240PublishedCited by 32 opinions
1Opinion of the Court
Opinion by Judge COYLE; Partial Concurrence and Partial Dissent by Judge REINHARDT.
COYLE, District Judge:
Taxpayer William Little appeals from the Tax Court’s decision imposing additions to tax for negligence, pursuant to 26 U.S.C. § 6653(a), and additions to tax for substantial understatement of tax, pursuant to 26 U.S.C. § 6661, for the tax years 1984, 1985, and 1986. The Commissioner determined that Taxpayer was not entitled to capital gain treatment on his real estate sales, because the properties sold were “dealer property,” *1447held primarily for sale to customers in the ordinary course of…
2Cases cited25 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Austin v. United StatesSupreme Court of the United States · 1993
- Helvering v. MitchellSupreme Court of the United States · 1938
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
20 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Estate of Robert G. Kluener, Donald E. Hathaway, Co-Executor, Charlotte J. Kluener v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1998
- Stanford v. CommissionerCourt of Appeals for the Fifth Circuit · 1998
- Custom Chrome, Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Larry L. Sather v. CIRCourt of Appeals for the Eighth Circuit · 2001
- United States v. TothCourt of Appeals for the First Circuit · 2022
27 more not listed; retrieve them via the Exa API.