Legal Opinion
Early v. Atkinson
Court of Appeals for the Fourth Circuit
Decided May 24, 1949No. 5873PublishedCited by 21 opinions
1Opinion of the Court
SOPER, Circuit Judge.
The estate of the taxpayer sued for a refund for $4510.88 net income taxes for the year 1941 on the ground that in that year he suffered a loss incurred in a transaction entered into for profit when he surrendered twenty-four life annuity contracts to the New York Life Insurance Company for $59,760 and accumulated dividends, upon which he had paid $72,000 in premiums. The District Judge held that the difference represented a loss deductible from income under Section 23(e) (2) of the Internal Revenue Code, 26 U.S.C.A. § 23(e) (2), and entered judgment for the plaintiff.…
2Cases cited25 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. TowerSupreme Court of the United States · 1946
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
20 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Jefferson v. CommissionerUnited States Tax Court · 1968
- Friedman v. CommissionerCourt of Appeals for the Fourth Circuit · 1989
- Visintainer v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951
- Loewi & Co. v. CommissionerUnited States Tax Court · 1954
- Britt's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
16 more not listed; retrieve them via the Exa API.