Legal Opinion
Spencer D. Stewart, Et Ux. v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided September 2, 1983No. 82-7497PublishedCited by 66 opinions
1Opinion of the CourtStewart, Justice
(Retired):
The Commissioner determined that the petitioners, Spencer D. and Mary Jane Stewart (referred to hereinafter as Stewart or the taxpayer 1 ), owed federal income taxes in the amounts of $210,751.13 for 1966 and $45,444.21 for 1967. On the taxpayer’s petition for review, the Tax Court 2 ruled: 1) that interest paid to Stewart by the City of Phoenix, Arizona (the City), pursuant to an agreement under which the City acquired immediate possession of Stewart’s water utility for a price to be determined in condemnation proceedings was not exempt from taxation under I.R.C. § 103(a); and 2)…
2Cases cited50 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
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3Cited by66 opinions
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Recklitis v. CommissionerUnited States Tax Court · 1988
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Leahy v. CommissionerUnited States Tax Court · 1986
- Seagate Technology v. CommissionerUnited States Tax Court · 1994
61 more not listed; retrieve them via the Exa API.