Legal Opinion

James E. And Frances J. Allison v. The United States

Court of Appeals for the Federal Circuit

Decided March 7, 1983No. Appeal 158-78PublishedCited by 25 opinions

1Opinion of the Court

DAVIS, Circuit Judge.

The Government appeals the judgment of the United States Claims Court, * which granted plaintiffs recovery of amounts which they had been required to pay by the Internal Revenue Service (IRS) as additional federal income taxes and deficiency interest for 1970. We reverse.

Taxpayer-plaintiff James E. Allison of Houston, Texas, invested in 1970 $10,459 in the R. Ashland Shepherd partnership (Shepherd). Shepherd during 1970 invested in a second partnership, Indonesian Marine Resources (Indomar), which in turn invested in a third partnership, Southeast Exploration (Souex).…

2Cases cited9 opinions

  1. South Corporation and Seal Fleet, Inc. v. The United StatesCourt of Appeals for the Federal Circuit · 1982
  2. United States v. Henry Prentiss & Co.Supreme Court of the United States · 1933
  3. Ruidoso Racing Association, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
  4. Orrisch v. CommissionerUnited States Tax Court · 1970
  5. Harris v. CommissionerUnited States Tax Court · 1974

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

3Cited by25 opinions

  1. Elrod v. CommissionerUnited States Tax Court · 1986
  2. Goldfine v. CommissionerUnited States Tax Court · 1983
  3. Vecchio v. CommissionerUnited States Tax Court · 1994
  4. Mary K.S. Ogden v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
  5. Estate of Carberry v. CommissionerCourt of Appeals for the Second Circuit · 1991

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

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