Legal Opinion
F. Norman Phelps and Alice Phelps v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided July 24, 1957No. 15386PublishedCited by 21 opinions
1Opinion of the Court
ORR, Circuit Judge.
We have for consideration a petition of F. Norman Phelps and Alice Phelps, hereafter petitioners, for a review of a decision of the Tax Court of the United States sustaining a determination by the Commissioner of Internal Revenue of a deficiency in petitioners’ Federal Income Taxes for the calendar year 1948.
The question presented is whether distributions from three related corporations in redemption of stock held by the petitioners were essentially equiva lent to the distribution of taxable dividends within the meaning of § 115(g), Internal Revenue Code of 1939, 26…
2Cases cited2 opinions
- Boyle v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
- Hugh H. Earle, Former Collector of Internal Revenue v. Angela MacEvoy WoodlawCourt of Appeals for the Ninth Circuit · 1957
3Cited by21 opinions
- Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Benjamin v. CommissionerUnited States Tax Court · 1976
- Blanche S. Benjamin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979
- Thomas Kerr and Barbara Kerr v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Lewis v. CommissionerUnited States Tax Court · 1966
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