Legal Opinion

American National Bank of Austin v. United States

Court of Appeals for the Fifth Circuit

Decided February 18, 1970No. 27301PublishedCited by 55 opinions

1Opinion of the Court

AINSWORTH, Circuit Judge:

The issue presented in this case is whether certain transactions of taxpayer, a national bank, with various municipal bond dealers during the years 1962-1964 are correctly characterized, as sale-repurchase transactions, as the District Court concluded, 1 or whether they should be held to be secured-Ioan transactions for tax purposes, as the Government contends. If they were sale-repurchase transactions, the municipal bond interest collected by taxpayer during the years 1962-1964 should have been excluded from taxpayer’s gross income as interest received on state…

2Cases cited23 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Phillips v. CommissionerSupreme Court of the United States · 1931
  3. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  4. John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
  5. United States v. Ada Belle Winthrop, Individually and as Under the Will of Guy L. Winthrop, DeceasedCourt of Appeals for the Fifth Circuit · 1969

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

3Cited by55 opinions

  1. Union Planters National Bank of Memphis v. United StatesCourt of Appeals for the Sixth Circuit · 1970
  2. Waterman Steamship Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
  3. G & R Corporation, a Delaware Corporation v. American Security & Trust Company, Max S. Kraft and Oscar MarguliesCourt of Appeals for the D.C. Circuit · 1975
  4. Hope v. CommissionerUnited States Tax Court · 1971
  5. McClure v. HopperCourt of Appeals for the Fifth Circuit · 1978

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

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