Legal Opinion
United States v. R. T. And Gertrude Woolsey
Court of Appeals for the Fifth Circuit
Decided March 3, 1964No. 20427PublishedCited by 29 opinions
1Opinion of the Court
GEWIN, Circuit Judge.
This ease involves Federal income taxes for the years 1955 through 1959. The Government has appealed from a final judgment of the U. S. District Court for the Southern District of Texas in favor of the taxpayers. The question presented is whether the amounts received by the taxpayers in consideration for the sale of their rights and interests in their partnership business which owned a management contract with a mutual insurance company are taxable as ordinary income or as a long term capital gain. The sale involved a total consideration of $171,500.00. Many of the facts…
2Cases cited14 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
9 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Kingsbury v. CommissionerUnited States Tax Court · 1976
- Pridemark, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1965
- General Guaranty Mortgage Co., Inc. v. Laurie W. Tomlinson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
- Flower v. CommissionerUnited States Tax Court · 1973
- Philip Long v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2014
24 more not listed; retrieve them via the Exa API.