Legal Opinion
Commissioner of Internal Revenue v. James B. Kelley and Lena S. Kelley, and John Waltman and Doris Waltman
Court of Appeals for the Fifth Circuit
Decided August 2, 1961No. 18185PublishedCited by 28 opinions
1Opinion of the Court
WISDOM, Circuit Judge.
The tax definition of a “collapsible corporation” illustrates again that the “difficulties of so-called interpretation arise when the legislature had no meaning at all; when the question which is raised on the statute never occurred to” the legislature.1 In the matter now before us our difficulties come from the certainty of the general congressional purpose in enacting Section 117(m) of the Internal Revenue Code of 1939 and the uncertainty of the meaning to be extracted from language of the section that is, perhaps, Janus-faced. It seems hardly possible that Congress…
2Cases cited19 opinions
- Lawrence v. CommissionerUnited States Tax Court · 1957
- J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Abbott v. CommissionerUnited States Tax Court · 1957
- Arthur L. Lawrence and Alma P. Lawrence v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Sidney v. CommissionerUnited States Tax Court · 1958
14 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- E. Keith Owens v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
- United States v. State of AlabamaCourt of Appeals for the Eleventh Circuit · 2015
- Howard Wallace Barbee and Bobby Joe Manziel v. United StatesCourt of Appeals for the Fifth Circuit · 1968
- Jack and Celia Farber v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Ellis Campbell, Jr., District Director of Internal Revenue v. Cen-Tex, Inc.Court of Appeals for the Fifth Circuit · 1967
23 more not listed; retrieve them via the Exa API.