Legal Opinion
Allison v. United States
District Court, M.D. Pennsylvania
Decided August 14, 1974No. Civ. 71-469PublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM
SHERIDAN, Chief Judge.
This is a civil action for the refund of $8,315.93 in income taxes, together with interest, which the taxpayer claims were erroneously and illegally assessed by the defendant for the calendar year 1962. The case was submitted on a stipulation of facts.
On March 1, 1959, the plaintiff, 1 Herbert L. Allison, received as a gift from his father, Herbert F. Allison, a portion of his father’s capital account in a partnership, the Lycoming Equipment Company. On that same date plaintiff entered into a partnership agreement and became a partner in the Lycoming Equipment…
2Cases cited27 opinions
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Dixon v. United StatesSupreme Court of the United States · 1965
- J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
- United States v. Garbutt Oil Co.Supreme Court of the United States · 1938
- Judie W. McDowell v. Anthony J. Celebrezze, Secretary of the United States Department of Health, Education and WelfareCourt of Appeals for the Fifth Circuit · 1962
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3Cited by3 opinions
- Edward J. Prescott and Wanda D. Prescott v. Commissioner of Internal Revenue, L. W. Simpson and Shirley Simpson v. United StatesCourt of Appeals for the Eighth Circuit · 1977
- Colella v. HecklerDistrict Court, E.D. Pennsylvania · 1985
- RABINOVICH v. COMMISSIONERUnited States Tax Court · 2004