Legal Opinion
Coffin v. United States
District Court, S.D. Alabama
Decided April 5, 1954No. Civ. A. 1109PublishedCited by 2 opinions
1Opinion of the Court
THOMAS, District Judge.
This is an action under Section 1346, Title 28 U.S.C.A., claiming refund of an alleged overpayment of taxes for the calendar year 1948. The alleged overpayment resulted from the determination of the Commissioner of Internal Revenue that certain income of the plaintiff was ordinary income, rather than income resulting from the sale of a capital asset; and that the plaintiff could not, by an amended return filed after the due date of the return, change to the installment method.
Findings of Fact
1. T. J. Rester purchased a tract of land to which the plaintiff held an…
2Cases cited6 opinions
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Appleby v. CommissionerUnited States Board of Tax Appeals · 1940
- Commissioner of Internal Rev. v. Appleby's EstateCourt of Appeals for the Second Circuit · 1941
- Gilford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
- United States v. KaplanSupreme Court of the United States · 1938
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3Cited by2 opinions
- Hahn v. CommissionerUnited States Tax Court · 1954
- Hahn v. CommissionerUnited States Tax Court · 1954