Legal Opinion

R. Paul Sprague and Mary G. Sprague v. United States

Court of Appeals for the Tenth Circuit

Decided August 14, 1980No. 78-1777PublishedCited by 10 opinions

1Opinion of the Court

MARK.EY, Chief Judge.

Action by R. Paul Sprague (Sprague) 1 for refund of federal income taxes. The district court held that the taxpayers’ stock transaction did not qualify for installment sale reporting and that they were therefore not entitled to a refund. Sprague v. United States, 42 A.F.T.R.2d 78-5877, 78-2 U.S.T.C. ¶ 9650 (W.D.Okla. Aug. 2, 1978). We reverse.

Background

R. Paul Sprague was a partner in Pelham Associates (Pelham), that owned stock in IHC, Inc. (IHC). Several banks held most of the stock as collateral for loans to Pelham.

Pelham contracted to sell the IHC stock in 1970.…

2Cases cited18 opinions

  1. Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
  2. W. B. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
  3. H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
  4. The Colorado Springs National Bank, a National Banking Association v. United StatesCourt of Appeals for the Tenth Circuit · 1974
  5. Toyota Industrial Trucks U. S. A., Inc. v. Citizens National Bank of Evans City v. Promat CorporationCourt of Appeals for the Third Circuit · 1979

13 more not listed; retrieve them via the Exa API.

3Cited by10 opinions

  1. American Coleman Co. v. Intrawest Bank of Southglenn, N.A.Court of Appeals for the Tenth Circuit · 1989
  2. Estate of Silverman v. CommissionerUnited States Tax Court · 1992
  3. Grannemann v. United StatesDistrict Court, E.D. Missouri · 1986
  4. Hyman v. CommissionerUnited States Tax Court · 1987
  5. Kenroy, Inc. v. CommissionerUnited States Tax Court · 1984

5 more not listed; retrieve them via the Exa API.

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