Legal Opinion

Commissioner of Internal Revenue v. Louis H. Mooneyhan

Court of Appeals for the Sixth Circuit

Decided December 5, 1968No. 18192PublishedCited by 34 opinions

1Opinion of the Court

CELEBREZZE, Circuit Judge.

This is a petition for review of a Tax Court judgment rendered in favor of Respondent Mooneyhan, hereinafter Respondent. The main question concerns Section 911(a) (2) of the 1954 Internal Revenue Code as it applies to payments Respondent received while working overseas.

In 1956, Iran borrowed funds to begin a comprehensive program of highway maintenance and construction. Lacking the pertinent resources, men, machines, and expertise in particular, Iran entered into a letter agreement on December 18, 1956, with the United States which provided generally that in return…

2Cases cited16 opinions

  1. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  2. United States v. CorrellSupreme Court of the United States · 1967
  3. Leo C. Cockrell, and Carol P. Cockrell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  4. Commissioner v. StidgerSupreme Court of the United States · 1967
  5. John J. Harvey and Irma P. Harvey v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960

11 more not listed; retrieve them via the Exa API.

3Cited by34 opinions

  1. Robert Rosenspan v. United StatesCourt of Appeals for the Second Circuit · 1971
  2. Francis J. Markey and Hazel L. Markey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1974
  3. Ludwig H. Brandl v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1975
  4. Leamy v. CommissionerUnited States Tax Court · 1985
  5. William J. Beer v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984

29 more not listed; retrieve them via the Exa API.

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