Legal Opinion

Danielson v. Commissioner

United States Tax Court

Decided August 29, 1968No. Docket Nos. 1779-63, 5489-63, 344-64, 473-64Published

Pursuant to the opinion and mandate in Commissioner v. Danielson, 378 F. 2d 771 (C.A. 3, 1967), and further evidence adduced, held, on the facts, that petitioners were not fraudulently induced by Thrift to sign noncompetition agreements in conjunction with the sale of their stock in Butler Loan. Thus, petitioners are bound by the agreements, and the amounts of consideration received therefor are taxable as ordinary income.

1Opinion of the Court

Carl L. Danielson and Pauline S. Danielson, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Danielson v. Commissioner

Docket Nos. 1779-63, 5489-63, 344-64, 473-64

United States Tax Court

50 T.C. 782; 1968 U.S. Tax Ct. LEXIS 77;

August 29, 1968, Filed

Decisions will be entered for the respondent.

Pursuant to the opinion and mandate in Commissioner v. Danielson, 378 F. 2d 771 (C.A. 3, 1967), and further evidence adduced, held, on the facts, that petitioners were not fraudulently induced by Thrift to sign noncompetition agreements in conjunction with the sale of their stock in…

2Cases cited19 opinions

  1. Griffith v. United Air Lines, Inc.Supreme Court of Pennsylvania · 1964
  2. Perry O. Hooper, as Trustee in Bankruptcy of Consolidated American Industries, Inc. v. Mountain States Securities CorporationCourt of Appeals for the Fifth Circuit · 1960
  3. John B. Janigan v. Frederick B. TaylorCourt of Appeals for the First Circuit · 1965
  4. Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
  5. Kardon v. National Gypsum Co.District Court, E.D. Pennsylvania · 1946

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