Legal Opinion
Dixon v. United States
Court of Appeals for the Second Circuit
Decided June 19, 1964No. 451, Docket 28752PublishedCited by 4 opinions
1Opinion of the Court
KAUFMAN, Circuit Judge.
The sole question presented by this appeal is whether profits attributable to-original issue discount on “commercial paper,” defined as short-term, non-interest-bearing commercial obligations, are-taxable at ordinary income or capital, gains rates under the Internal Revenue-Code of 1939.1
The relevant facts in this case are free-from dispute. Thus, the plaintiffs” amended complaint reveals that during the taxable year 1952, the taxpayers or their spouses or decedents were partners-in the investment firm of Carl M. Loeb-Rhoades & Co., a member of the New York and American…
2Cases cited10 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner of Internal Revenue v. CaulkinsCourt of Appeals for the Sixth Circuit · 1944
- Commissioner of Internal Revenue v. J. I. Morgan and Frances MorganCourt of Appeals for the Ninth Circuit · 1959
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3Cited by4 opinions
- Joseph I. Lubin and Evelyn J. Lubin, and Estate of Joseph Eisner, Deceased, Helen Eisner, and Helen Eisner v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
- Liberty National Life Insurance Company v. United StatesCourt of Appeals for the Fifth Circuit · 1979
- Dixon v. United StatesCourt of Appeals for the Second Circuit · 1964
- Midland-Ross Corporation v. United StatesCourt of Appeals for the Sixth Circuit · 1964