Legal Opinion
Harold T. And Marie T. Paulsen v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided August 16, 1983No. 82-7329PublishedCited by 7 opinions
1Opinion of the Court
NORRIS, Circuit Judge:
Pursuant to a merger plan between a stock savings and loan association and a mutual savings and loan association, shareholders in the stock association exchanged their “guaranty shares” for passbook accounts and time certificates of deposit in the mutual association. The Tax Court, believing that it was “constrained to follow the guidelines of several circuit court decisions holding [transactions such as this one to be tax free],” held the exchange to be a stock for stock transaction not taxable under 26 U.S.C. § 354. Paulsen v. Commissioner, 78 T.C. 291, 302-303, 303 n.…
2Cases cited10 opinions
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
- John A. Nelson Co. v. HelveringSupreme Court of the United States · 1935
- Society for Sav. in Cleveland v. BowersSupreme Court of the United States · 1955
- York v. Federal Home Loan Bank BoardCourt of Appeals for the Fourth Circuit · 1980
5 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Paulsen v. CommissionerSupreme Court of the United States · 1985
- Harbinger Capital Partners Master Fund I, Ltd. v. Granite Broadcasting Corp.Court of Chancery of Delaware · 2006
- First Federal Sav. & Loan Ass'n of Temple v. United StatesDistrict Court, W.D. Texas · 1988
- Estate of Silverman v. CommissionerUnited States Tax Court · 1992
- Estate of Silverman v. CommissionerUnited States Tax Court · 1992
2 more not listed; retrieve them via the Exa API.