Legal Opinion
Durand A. Holladay and Blanche F. Holladay v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided July 9, 1981No. 80-5274PublishedCited by 22 opinions
1Opinion of the Court
FRANK M. JOHNSON, Jr., Circuit Judge:
Durand A. Holladay 1 petitioned the United States Tax Court for a review of the federal income tax deficiencies totalling $589,396 assessed against him by the Commissioner of Internal Revenue for calendar years 1971 through 1973. 2 Holladay appeals from the Tax Court’s decision in favor of the Commissioner under 26 U.S.C.A. § 7482. This case was consolidated for oral argument with Boynton v. Commissioner, 649 F.2d 1168 (5th Cir. 1981), and should be read in conjunction with it.
I. Facts
The factual situation involved is essentially undisputed. 3 In 1970,…
2Cases cited9 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Audrey M. Thompson, Florence Ain & Gregory Ain, Dorothy E. Kahan & Robert Kahan, Nana Berman & William Berman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Orrisch v. CommissionerUnited States Tax Court · 1970
4 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Compaq Computer Corporation & Subsidiaries v. CommissionerCourt of Appeals for the Fifth Circuit · 2001
- Lewis Arthur Merryman v. Commissioner of Internal Revenue, Michael A. Carroll and Margaret W. Carroll v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1989
- Klamath Strategic Investment Fund, LLC v. United StatesDistrict Court, E.D. Texas · 2007
- Joe T. Boynton and Helen J. Boynton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
- Goldfine v. CommissionerUnited States Tax Court · 1983
17 more not listed; retrieve them via the Exa API.