Legal Opinion
Edmondson v. Allen-Russell Ford, Inc.
Court of Appeals for the Fifth Circuit
Decided July 28, 1978No. 76-3773PublishedCited by 32 opinions
1Opinion of the Court
THORNBERRY, Circuit Judge:
If Justice Holmes was correct that “[tjaxes are what we pay for civilized society,” 1 then the question in this case is how much civilization the taxpayer will be required to purchase.
More precisely, we are asked to decide the proper tax treatment of a pro rata distribution of cash to shareholders in the course of a corporate reorganization. The taxpayer contends that this “boot” should be taxed as a long-term capital gain, while the government argues that it has “the effect of the distribution of a dividend” within the meaning of 26 U.S.C. § 356(a)(2) and should…
2Cases cited31 opinions
- United States v. PhellisSupreme Court of the United States · 1921
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
26 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Palmer v. Champion MortgageCourt of Appeals for the First Circuit · 2006
- Anderson Bros. Ford v. ValenciaSupreme Court of the United States · 1981
- Olga Valencia and Miguel Gonzalez v. Anderson Bros. Ford and Ford Motor Credit CompanyCourt of Appeals for the Seventh Circuit · 1980
- Ryan v. Occidental Petroleum Corp.Court of Appeals for the Fifth Circuit · 1978
- Bessie Lee Harris v. Tower Loan of Mississippi, Inc.Court of Appeals for the Fifth Circuit · 1980
27 more not listed; retrieve them via the Exa API.