Legal Opinion

Perrault v. Commissioner

Court of Appeals for the Tenth Circuit

Decided April 19, 1957No. Nos. 5465-5476PublishedCited by 9 opinions

1Per curiam

Petitioners seek to review decisions of the Tax Court involving the personal income tax liabilities of the individual petitioners for the years 1946 and 1948 and the corporate income tax liability of the Allied Paint Company for the years 1947, 1948, and 1949. The Tax Court has determined that income claimed by the individual petitioners as proceeds from a sale and taxable as a capital gain should be treated as dividend income and subject to normal rates.1 The corporate adjustments are routine if the Tax Court’s position is sound as applied to the individual petitioners.

The basic transaction…

2Cases cited2 opinions

  1. Gunn v. CommissionerUnited States Tax Court · 1955
  2. George C. Houck, Jr. v. H. I. Hinds, Individually and as Collector of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954

3Cited by9 opinions

  1. Miami Valley Broadcasting Corp. v. United StatesUnited States Court of Claims · 1974
  2. U. S. Asiatic Co. v. CommissionerUnited States Tax Court · 1958
  3. Bruce v. KnoxDistrict Court, D. Minnesota · 1960
  4. Zenith Sportswear Co. v. CommissionerUnited States Tax Court · 1957
  5. Ainslie Perrault and Mae Frances Perrault v. Commissioner of Internal Revenue, Repsondent. R. M. Gunn v. Commissioner of Internal Revenue, (Two Cases). Alma L. Gunn v. Commissioner of Internal Revenue, Arthur T. Saunders v. Commissioner of Internal Revenue, Margueret A. Saunders v. Commissioner of Internal Revenue, Arthur T. Saunders and Margueret A. Saunders v. Commissioner of Internal Revenue, R. E. Stanford v. Commissioner of Internal Revenue, Peggy Q. Stanford v. Commissioner of Internal Revenue, Ainslie Perrault v. Commissioner of Internal Revenue, Mae Frances Perrault v. Commissioner of Internal Revenue, Allied Paint Manufacturing Co. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1957

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