Legal Opinion
Coyle v. United States
Court of Appeals for the Fourth Circuit
Decided June 6, 1968No. 11828PublishedCited by 8 opinions
1Opinion of the Court
SOBELOFF, Circuit Judge:
Our task in this tax refund case is to apply to a stipulated set of facts an unambiguous, if involved, network of statutes to determine whether the proceeds from a transfer of corporate stock are to be taxed as capital gains or ordinary income. The District Court ruled that money which the taxpayer received in exchange for the shares of a corporation he controlled to a corporation wholly owned by his sons should be treated as a capital gain. We disagree and reverse ithe judgment.
In 1958, taxpayer George L. Coyle, Sr. (now deceased) transferred 66 shares of Coyle &…
2Cases cited9 opinions
- Brown Shoe Co. v. CommissionerSupreme Court of the United States · 1950
- Eva D. Bradbury v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1962
- Charles P. Ballenger, Jr., and Myrtle S. Ballenger v. United StatesCourt of Appeals for the Fourth Circuit · 1962
- Beatrice Levin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Charles P. Hasbrook and Marcia B. Hasbrook v. United StatesCourt of Appeals for the Second Circuit · 1965
4 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Niedermeyer v. CommissionerUnited States Tax Court · 1974
- Fehrs Finance Co. v. CommissionerUnited States Tax Court · 1972
- Cox v. CommissionerUnited States Tax Court · 1982
- Webb v. CommissionerUnited States Tax Court · 1976
- Continental Bankers Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
3 more not listed; retrieve them via the Exa API.