Legal Opinion
Exchange Security Bank v. United States of America, Ellen Gregg Ingalls v. United States
Court of Appeals for the Fifth Circuit
Decided April 19, 1974No. 73-1335PublishedCited by 7 opinions
1Opinion of the Court
COLEMAN, Circuit Judge:
The District Court denied plaintiff-taxpayers’ claim for a tax refund. We reverse.
The operative facts begin with the dispute between Robert Ingalls, Jr., president of the family corporation, In-galls Iron Works, Inc. (the Company), and his mother Ellen Gregg Ingalls, over 2,287 shares of company stock. Under a 1943 agreement, the Company had an option to purchase these shares at the death of its owner, Robert Ingalls, Sr. Upon his death in 1951, Mrs. Ingalls became president of the Company. The Company did not exercise its stock purchase option.
In 1952, the son, Robert…
2Cases cited21 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Corliss v. BowersSupreme Court of the United States · 1930
- James v. United StatesSupreme Court of the United States · 1961
- Commissioner v. HansenSupreme Court of the United States · 1959
- Burnet v. WellsSupreme Court of the United States · 1933
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3Cited by7 opinions
- Milenbach v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2003
- Milenbach v. CommissionerCourt of Appeals for the Ninth Circuit · 2003
- Marcaccio v. CommissionerUnited States Tax Court · 1995
- Koch Industries, Inc. and Subsidiaries v. United StatesDistrict Court, D. Kansas · 2008
- Miller v. Comm'rUnited States Tax Court · 2006
2 more not listed; retrieve them via the Exa API.