Legal Opinion
Joe M. Smith and Florence P. Smith v. Commissioner of Internal Revenue, Henry v. Nielsen and Margaret E. Nielsen v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided April 2, 1970No. 22945, 22946PublishedCited by 8 opinions
1Opinion of the Court
KILKENNY, Circuit Judge:
Petitioners seek a review of the decision of the tax court in connection with income tax deficiencies for the years 1962 and 1963.
The issues presented to us for review are:(1) Whether Joe M. Smith, Robert H. Anderson and Henry V. Nielsen, shareholders in Smith-Nielsen Manufacturing Co., an electing small business corporation, must report as taxable income, payments received in reduction of a corporation indebtedness to them. Their bases for the indebtedness have been reduced, but not to zero, by virtue of adjustments for corporate net operating losses.(2) Whether Joe…
2Cases cited5 opinions
- Commercial Solvents Corp. v. CommissionerUnited States Tax Court · 1964
- San Francisco Stevedoring Co. v. CommissionerUnited States Tax Court · 1947
- Smith v. CommissionerUnited States Tax Court · 1967
- Standard Lumber Co. v. CommissionerUnited States Tax Court · 1960
- Standard Lumber Co., Formerly Pilot Rock Lumber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
3Cited by8 opinions
- Anderson v. CommissionerUnited States Tax Court · 1971
- Cornelius v. CommissionerUnited States Tax Court · 1972
- Cornelius v. CommissionerCourt of Appeals for the Fifth Circuit · 1974
- Paul G. Cornelius v. Commissioner Of Internal RevenueCourt of Appeals for the Fifth Circuit · 1974
- Albert v. CommissionerUnited States Tax Court · 1980
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