Legal Opinion
Cates v. Commissioner
Court of Appeals for the Eleventh Circuit
Decided October 11, 1983No. 82-8363PublishedCited by 4 opinions
1Opinion of the Court
ALLGOOD, District Judge:
This appeal is from a decision of the United States Tax Court1 holding that the appellants/taxpayers (taxpayers) had realized short term capital gains from the sale of their stock options in Metro “400,” Inc. (Metro) and that taxpayers were liable for a 5 percent addition to tax pursuant to Section 6653(a) of the Internal Revenue Code of 1954 [26 U.S.C. 6653(a)].
In early 1972 Calvin Thomas (Calvin) learned that 258.477 acres of land in Alpharetta, Georgia (located just outside of Atlanta) were for sale. He discussed the purchase of this land with the appellants,…
2Cases cited9 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Ellis Banking Corporation v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1982
- Robert JONES, Plaintiff-Appellant, v. LUMBERJACK MEATS, INC., a Corporation, Defendant-AppelleeCourt of Appeals for the Eleventh Circuit · 1982
- Fogel v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Oren F. Potito, Oren F. Potito and Helen M. Potito v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
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3Cited by4 opinions
- Estate of Elbert B. Whitt, Loyd Whitt v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- John H. Lary, Jr., and Sherry S. Lary v. United StatesCourt of Appeals for the Eleventh Circuit · 1986
- McCormack v. CommissionerUnited States Tax Court · 1987
- Goodwyn Cates v. Commissioner Of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1983