Legal Opinion
Bornstein v. United States
United States Court of Claims
Decided May 14, 1965No. 270-61; No. 271-61; No. 272-61; No. 273-61PublishedCited by 65 opinions
1Opinion of the Court
CowEN, 0Thief Judge,
delivered the opinion of the court:
This is a suit for refund of income taxes, plus interest, arising from the distribution of certain funds by a corporation of which plaintiffs are shareholders. The defendant treated the distribution as ordinary income to plaintiffs, pursuant to 26 U.S.C. (I.R.C. 1939) § 117 (m) (1952 Ed.) [Collapsible Corporations]. Plaintiffs concede that the distributions were properly taxable under that statute as ordinary income unless the Commissioner of Internal Eevenue is es-topped or otherwise prohibited from assessing the deficiency because of…
2Cases cited22 opinions
- Federal Crop Ins. Corp. v. MerrillSupreme Court of the United States · 1947
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Utah Power & Light Co. v. United StatesSupreme Court of the United States · 1917
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- International Business MacHines Corporation v. The United StatesUnited States Court of Claims · 1965
17 more not listed; retrieve them via the Exa API.
3Cited by65 opinions
- Emma R. Dorl v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974
- Jackson v. United StatesUnited States Court of Claims · 1978
- Karl F. Knetsch and Eva Fay Knetsch v. The United StatesUnited States Court of Claims · 1965
- Canelo v. CommissionerUnited States Tax Court · 1969
- Vons Companies, Inc. v. United StatesUnited States Court of Federal Claims · 2001
60 more not listed; retrieve them via the Exa API.