Legal Opinion

Charles A. Sammons, Individually, and Estate of Rosine S. Sammons, Deceased, Charles A. Sammons, Independent v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided January 19, 1973No. 71-3065PublishedCited by 90 opinions

ON PETITION FOR REHEARING

1Opinion of the Court

CLARK, Circuit Judge:

The per curiam opinion of this court dated August 11, 1972 is withdrawn and the following opinion is adopted as the opinion of the court.

The intricate facts of the several corporate transactions involved in this case are fully set out in the Tax Court opinion in Charles A. Sammons, 30 T.C.M. 626 (1971), and need not be repeated here. Suffice it to say that the facts outlined herein are highly simplified. Sammons, the prime mover in this inter-corporate world, owned 99% of Reserve Life Insurance Company, which in turn owned a substantial interest in Standard Steel Works,…

2Cases cited22 opinions

  1. United States v. United States Gypsum Co.Supreme Court of the United States · 1948
  2. Commissioner v. DubersteinSupreme Court of the United States · 1960
  3. United States v. GeneresSupreme Court of the United States · 1972
  4. Rushing v. CommissionerUnited States Tax Court · 1969
  5. W. B. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971

17 more not listed; retrieve them via the Exa API.

3Cited by90 opinions

  1. Magnon v. CommissionerUnited States Tax Court · 1980
  2. Stinnett's Pontiac Service, Inc., Richard W. Stinnett and Gay P. Stinnett v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1984
  3. James and Martha Kuper and Charles and Kathleen Kuper, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Fifth Circuit · 1976
  4. Rapid Electric Co. v. CommissionerUnited States Tax Court · 1973
  5. Gulf Oil Corporation, in No. 89-2049 v. Commissioner of Internal Revenue. Commissioner of Internal Revenue, in No. 89-2050 v. Gulf Oil CorporationCourt of Appeals for the Third Circuit · 1990

85 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API