Legal Opinion
Bar L Ranch, Inc., and in Intervention-Appellant v. Robert L. Phinney, United States of America, in Intervention-Appellee
Court of Appeals for the Fifth Circuit
Decided May 14, 1970No. 27836PublishedCited by 47 opinions
1Opinion of the Court
DYER, Circuit Judge.
In reporting the amount of capital gain realized in a transaction in which it received a note and accounts receivable having a combined face value of $118,- 100.07, taxpayer valued the note and accounts at substantially below their face. The Commissioner of Internal Revenue determined they should be valued at their face value. The District Court found that the taxpayer failed to show the incorrectness of the Commissioner’s assessment and the correct value upon which the tax should have been assessed and entered judgment for the Government. We reverse and remand.
Bar L Ranch…
2Cases cited24 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- United States v. DavisSupreme Court of the United States · 1962
- Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- United States v. Ada Belle Winthrop, Individually and as Under the Will of Guy L. Winthrop, DeceasedCourt of Appeals for the Fifth Circuit · 1969
- United States v. Joseph G. LeaseCourt of Appeals for the Second Circuit · 1965
19 more not listed; retrieve them via the Exa API.
3Cited by47 opinions
- United States v. JanisSupreme Court of the United States · 1976
- Ramon Portillo and Dolores Portillo v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
- United States v. Felix Benitez RexachCourt of Appeals for the First Circuit · 1973
- Archie Dale Carson v. United StatesCourt of Appeals for the Fifth Circuit · 1977
- United States v. Dorothy R. GarberCourt of Appeals for the Fifth Circuit · 1979
42 more not listed; retrieve them via the Exa API.