Dougherty v. Commissioner
United States Tax Court
Held, petitioners' motion to withdraw conditionally their election to have the provisions of sec. 962, I.R.C. 1954, apply with respect to their taxable year 1963 is denied.
1Opinion of the Court
SUPPLEMENTAL OPINION
Tannenwald, Judge:
In our Court-reviewed opinion disposing of the substantive issues involved in this case (60 T.C. 917), we held that petitioner Albert L. Dougherty had made an effective election under section 9621 to be taxed at corporate rates on the amount includable in his gross income for 1963 under section 951(a). The parties had stipulated as to the election2 and the sole issue before the Court was whether the election had been timely made. See 60 T.C. at 938-942.
Wo also held in our original opinion that the amount properly includable in petitioner’s gross income…
2Cases cited22 opinions
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Pollack v. CommissionerUnited States Tax Court · 1966
- Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
- Dougherty v. CommissionerUnited States Tax Court · 1973
17 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Haft Trust v. CommissionerUnited States Tax Court · 1974
- Tipps v. CommissionerUnited States Tax Court · 1980
- American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
- Dunavant v. CommissionerUnited States Tax Court · 1974
- Fehrs v. United StatesUnited States Court of Claims · 1977
9 more not listed; retrieve them via the Exa API.