Legal Opinion
Harold P. Dahlgren v. United States
Court of Appeals for the Fifth Circuit
Decided August 12, 1977No. 75-3263PublishedCited by 14 opinions
1Opinion of the Court
TUTTLE, Circuit Judge:
The issue before the jury in this income tax refund suit was whether ownership by taxpayer of 79.975% of the capital stock of the company to which he made a sale of depreciable property was ownership of “more than 80 percent in value of the outstanding stock . . . .” [emphasis added] within contemplation of § 1239(a)(1) of the Internal Revenue Code of 1954. 1
The jury answered special interrogatories stating that they found from a preponderance of the evidence that “[Dahlgren] did not own more than 80% in value ‘of the stock of Dahlgren Manufacturing Company.’ ” The…
2Cases cited11 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Jane Perlman v. C. Russell Feldmann, Newport Steel CorporationCourt of Appeals for the Second Circuit · 1955
- Oscar J. Marshall v. Isthmian Lines, Inc.Court of Appeals for the Fifth Circuit · 1964
- Leon Stoller and Audrey Stoller v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- United States v. Curtis L. Parker and Martha ParkerCourt of Appeals for the Fifth Circuit · 1967
6 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Jose Bueno, Leon Trevino and Victor Alegria, Cross-Appellants v. City of Donna, Cross-AppelleesCourt of Appeals for the Fifth Circuit · 1983
- Jones v. MilesCourt of Appeals for the Fifth Circuit · 1981
- United States v. RyanCourt of Appeals for the Eleventh Circuit · 1995
- Margaret P. Katch, as Independent Personal Representative of the Estate of Richard P. Katch, Deceased v. Speidel, Division of Textron, Inc.Court of Appeals for the Sixth Circuit · 1984
- Philip Morris, Inc. v. CommissionerUnited States Tax Court · 1991
9 more not listed; retrieve them via the Exa API.