Legal Opinion
Slappey Drive Industrial Park v. United States
Court of Appeals for the Fifth Circuit
Decided October 19, 1977No. Nos. 75-1885 thru 75-1896PublishedCited by 39 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge.
This tax refund suit involves seven closely held real estate development corporations that Spencer C. Walden, Jr. organized and manages. The first issue, the one most extensively debated by the parties, is whether certain purported debts that the corporations owed their shareholders should be treated for tax purposes as contributions to capital. The second issue is whether one of the seven corporations was formed primarily for tax-avoidance purposes, thus precluding it from claiming the corporate surtax exemption. The final question is whether three parcels of land…
2Cases cited23 opinions
- Malat v. RiddellSupreme Court of the United States · 1966
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- United States v. Ada Belle Winthrop, Individually and as Under the Will of Guy L. Winthrop, DeceasedCourt of Appeals for the Fifth Circuit · 1969
18 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Ernest J. Saviano and Margaret Saviano v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1985
- American Offshore, Inc. v. CommissionerUnited States Tax Court · 1991
- Lloyd M. Shumaker v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1981
- Official Comm. Unsecured Creditors of HH Liquidation, LLC v. Comvest Grp. Holdings, LLC (In re HH Liquidation, LLC)United States Bankruptcy Court, D. Delaware · 2018
- Ocmulgee Fields, Inc. v. Comm. of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2010
34 more not listed; retrieve them via the Exa API.