Legal Opinion
Gray v. Commissioner
Court of Appeals for the Ninth Circuit
Decided September 21, 1977No. Nos. 75-1041 to 75-1046PublishedCited by 9 opinions
1Opinion of the Court
SNEED, Circuit Judge:
Taxpayers appeal from a decision of the Tax Court holding that what in form was a sale of taxpayers’ stock in a wholly owned corporation was in substance a liquidation of the corporation. John D. Gray, 56 T.C. 1032 (1971). The case demonstrates anew the need to elevate substance over form in interpreting a sophisticated code of tax laws where slight differences in a transaction’s design can lead to widely divergent tax results. It also demonstrates, however, the difficulties in determining the substance of a transaction when dealing with complex business arrangements in…
2Cases cited21 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. TowerSupreme Court of the United States · 1946
- Higgins v. SmithSupreme Court of the United States · 1940
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
16 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- E. Keith Owens v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
- Ralph Furrer and Rosemarie Furrer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1977
- Roy C. Wilkin v. United StatesCourt of Appeals for the Ninth Circuit · 1987
- Arthur J. Gray and Esther Gray v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1981
- Gray v. CommissionerUnited States Tax Court · 1979
4 more not listed; retrieve them via the Exa API.