Legal Opinion

Perma-Rock Products, Inc. v. United States

District Court, D. Maryland

Decided September 28, 1973No. Civ. 21408-K, 21409-K, and 70-403-KPublishedCited by 6 opinions

1Opinion of the Court

FRANK A. KAUFMAN, District Judge.

In these three cases, Perma-Rock Products, Inc. (“Perma-Rock”), Jack 0. Chertkof (“Jack”) and Sophie Chertkof (the two Chertkofs are sometimes hereinafter referred to as “the Chertkofs”) seek the refund of federal income taxes under 28 U.S.C. § 1346(a)(1). Certain of the issues originally posed in these cases are not discussed herein as they have been otherwise determined or handled. 1

The Chertkofs contend in these cases that the Internal Revenue Service (IRS) erroneously treated (1) in 1964 a $2000 payment to Jack by Perma-Rock as a dividend rather than an…

2Cases cited19 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  3. Kornhauser v. United StatesSupreme Court of the United States · 1928
  4. Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
  5. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960

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3Cited by6 opinions

  1. Chertkof v. United StatesCourt of Appeals for the Fourth Circuit · 1982
  2. Jack O. Chertkof and Sophie Chertkof v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1981
  3. Chertkof v. CommissionerUnited States Tax Court · 1976
  4. Chertkof v. CommissionerUnited States Tax Court · 1976
  5. Frazier v. CommissionerUnited States Tax Court · 1994

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