Legal Opinion
Nash v. United States
Court of Appeals for the Fifth Circuit
Decided July 2, 1969No. Nos. 26928-26930PublishedCited by 1 opinion
1Opinion of the Court
TUTTLE, Circuit Judge:
This appeal presents the issue as to the taxability of a reserve for bad debts, set up by individual taxpayers, upon their transfer of the accounts receivable owned by the taxpayers, to controlled corporations, under § 351 of the 1954 Internal Revenue Code.1
These consolidated suits were brought to recover federal income taxes for the year 1961. The taxes had been paid by the taxpayers, James G. Nash and his wife by joint return and Birmingham Trust National Bank as trustee under the James G. Nash, Jr. Trust and under the Margaret Nash Trust. These persons were partners…
2Cases cited7 opinions
- West Seattle National Bank of Seattle v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
- S. Rossin & Sons v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
- Estate of Heinz Schmidt, Deceased, and Charlotte Schmidt v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1966
- Peabody Coal Co. v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Seventh Circuit · 1931
- Schmidt v. CommissionerUnited States Tax Court · 1964
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