Legal Opinion

Estate of Alper v. Commissioner

United States Tax Court

Decided November 20, 1961No. Docket No. 79162Unpublished

Held, the gains realized by Louis and Reva Alper during the taxable years 1950 and 1951 upon their stock in the five Manor corporations are taxable as ordinary income under the provisions of section 117(m) of the Internal Revenue Code of 1939.

1Opinion of the Court

Estate of Louis Alper, Deceased, Sam Alper, Executor, and Reva Alper, Surviving Wife v. Commissioner.

Estate of Alper v. Commissioner

Docket No. 79162.

United States Tax Court

T.C. Memo 1961-316; 1961 Tax Ct. Memo LEXIS 33; 20 T.C.M. (CCH) 1626; T.C.M. (RIA) 61316;

November 20, 1961

Held, the gains realized by Louis and Reva Alper during the taxable years 1950 and 1951 upon their stock in the five Manor corporations are taxable as ordinary income under the provisions of section 117(m) of the Internal Revenue Code of 1939.

Phillip Nusholtz, Esq., National Bank Bldg., Detroit, Mich., for the…

2Cases cited10 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  3. James v. United StatesSupreme Court of the United States · 1961
  4. Commissioner v. WilcoxSupreme Court of the United States · 1946
  5. Sidney v. CommissionerUnited States Tax Court · 1958

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