Legal Opinion
Herbert B. Cline, Jr., and Brisy Cline, John C. Cline and Mildred Cline v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided March 25, 1980No. 77-1754, 77-1755PublishedCited by 8 opinions
1Opinion of the Court
LIVELY, Circuit Judge.
The question in this case is whether certain payments received by the taxpayers in the years 1967-1971 were entitled to be treated as long term capital gains, as reported by them, or as ordinary income as contended by the Commissioner. The facts in the two cases are identical, and the cases were consolidated in the Tax Court and in this court. The decision of the Tax Court is reported at 67 T.C. 889 (1977). The stipulated facts are set forth in detail in the opinion of the Tax Court and will be summarized here.
Prior to December 30, 1966 the taxpayers Herbert B. Cline and…
2Cases cited9 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
4 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- William H. Zuhone, Jr. And Audra M. Zuhone v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1989
- National-Standard Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
- Francis E. Gartrell and Mabel L. Gartrell v. United StatesCourt of Appeals for the Sixth Circuit · 1980
- Frederick Wuebker and Ruth Wuebker v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2000
- Forrer v. CommissionerUnited States Tax Court · 1981
3 more not listed; retrieve them via the Exa API.