Legal Opinion

Covered Wagon, Inc. v. Commissioner

Court of Appeals for the Eighth Circuit

Decided December 13, 1966No. Nos. 18320-18323PublishedCited by 10 opinions

1Opinion of the Court

DUNCAN, Senior District Judge.

This case is before the Court on petitions to review the decision of the Tax Court of the United States involving the application of § 337(a)1 of the Internal Revenue Code of 1954, to the compensation for taking of the corporate petitioner’s real property by the United States under Title 40 § 258a 2 U.S.C. The facts *631are not in dispute and were before the Tax Court on stipulation. The principal questions for review by this Court are:(1) The date of the “sale” within the meaning of the condemnation statute and § 337(a), supra;(2) The date or dates when the capital…

2Cases cited19 opinions

  1. United States v. MillerSupreme Court of the United States · 1943
  2. Fribourg Navigation Co. v. CommissionerSupreme Court of the United States · 1966
  3. Kieselbach v. CommissionerSupreme Court of the United States · 1943
  4. Wood Harmon Corporation v. United StatesCourt of Appeals for the Second Circuit · 1963
  5. Towanda Textiles, Inc. v. United StatesUnited States Court of Claims · 1960

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3Cited by10 opinions

  1. Central Tablet Manufacturing Co. v. United StatesSupreme Court of the United States · 1974
  2. United States v. 162.20 Acres of Land, More or Less, Situated in Clay County, State of Mississippi, and F. E. UithovenCourt of Appeals for the Fifth Circuit · 1981
  3. Casalina Corp. v. CommissionerUnited States Tax Court · 1973
  4. The Covered Wagon, Inc., Grace D. Ryan, Transferee, Mina Benson, Transferee, Fritz W. Benson, Transferee v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. The Covered Wagon, Inc., Grace D. Ryan, Transferee, Mina Benson, Transferee, Fritz W. Benson, TransfereeCourt of Appeals for the Eighth Circuit · 1966
  5. A. T. NEWELL REALTY CO. v. COMMISSIONERUnited States Tax Court · 1969

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