Legal Opinion
United States v. W. B. And Edna B. Williams
Court of Appeals for the Fifth Circuit
Decided May 24, 1968No. 19-70013PublishedCited by 32 opinions
1Opinion of the Court
SIMPSON, Circuit Judge:
This appeal involves a deficiency in income tax for the year 1956 in the amount of $108,839.06, plus interest and costs.
The sole issue presented is whether a sum of money received by appellee Williams (sometimes herein, taxpayer) constituted a loan or prepayment of rent. The proceeds are taxable only if determined to be prepayment of rent.1
Williams owned timber lands in four counties in Georgia. On December 28, 1956, he entered into a written agreement granting Owens-Illinois Glass Company the right to cut and purchase timber growing on his land for a period of…
2Cases cited15 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Weiss v. StearnSupreme Court of the United States · 1924
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
10 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- BJR Corp. v. CommissionerUnited States Tax Court · 1976
- Illinois Power Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Union Mutual Life Insurance Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the First Circuit · 1978
- New England Tank Industries, Inc. v. CommissionerUnited States Tax Court · 1968
- City Gas Company of Florida v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1982
27 more not listed; retrieve them via the Exa API.