Legal Opinion
United States v. Wernentin
Court of Appeals for the Eighth Circuit
Decided December 27, 1965No. Nos. 17633, 17688PublishedCited by 21 opinions
1Opinion of the Court
BLACKMUN, Circuit Judge.
At issue here is the character — as long-term capital gain or as ordinary income — • of a partnership’s net receipts under certain Dairy Queen contracts during the calendar years 1951-1953, inclusive.
The taxpayers are Fred C. Wernentin and his wife Esther and Robert L. Jester and his wife Bobbette. The partnership, known as Wernentin and Jester, was originally one between the two men but on January 1, 1952, was expanded to include their wives.
The net receipts in question were reported in the filed partnership returns as ordinary income and were correspondingly…
2Cases cited18 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Brotherhood of Railway & Steamship Clerks, Freight Handlers, Express & Station Employees v. Association for the Benefit of Non-Contract EmployeesSupreme Court of the United States · 1965
- Orla E. Watson and Edith Watson v. United StatesCourt of Appeals for the Tenth Circuit · 1955
- United States v. ZacksSupreme Court of the United States · 1963
- Eastmount Construction Company and American Surety Company v. Transport Manufacturing & Equipment CompanyCourt of Appeals for the Eighth Circuit · 1962
13 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Bell Intercontinental Corporation v. The United StatesUnited States Court of Claims · 1967
- Thomas J. Durkin, Colette A. Durkin, Jerome A. Grossman and Sybil G. Grossman v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1989
- Consolidated Foods Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1978
- Jefferson-Pilot Corp. v. CommissionerUnited States Tax Court · 1992
- The Conde Nast Publications, Inc., and Cross-Appellant v. United States of America, and Cross-AppelleeCourt of Appeals for the Second Circuit · 1978
16 more not listed; retrieve them via the Exa API.