Legal Opinion

Constance M. Bishop v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided March 24, 1965No. 15894PublishedCited by 34 opinions

1Opinion of the Court

SHACKELFORD MILLER, Jr., Circuit Judge.

The taxpayer, Constance M. Bishop, a widow of more than 65 years of age, borrowed in 1954 $159,000.00 from The Society for Savings, Cleveland, Ohio, using as Collateral securities which were not tax-exempt obligations under Section 265(2), Internal Revenue Code. The proceeds of this loan were used to purchase stock and debentures of a corporation, Producing Properties, Inc., which, likewise, were not tax-exempt obligations.

On June 6, 1955, the taxpayer established an agency account at The Cleveland Trust Co., Cleveland, Ohio, to which she transferred…

2Cases cited9 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  4. Burnet v. HoustonSupreme Court of the United States · 1931
  5. Reinecke v. SpaldingSupreme Court of the United States · 1930

4 more not listed; retrieve them via the Exa API.

3Cited by34 opinions

  1. Rose v. CommissionerUnited States Tax Court · 1987
  2. James L. Rose and Judy S. Rose v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
  3. G. M. Leasing Corp. v. The United States of America, George I. Norman, Iii, IntervenorCourt of Appeals for the Tenth Circuit · 1975
  4. Illinois Terminal Railroad Company v. The United StatesUnited States Court of Claims · 1967
  5. Leslie v. CommissionerUnited States Tax Court · 1968

29 more not listed; retrieve them via the Exa API.

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