Legal Opinion
E. H. Winn, Jr. And Betty Lee Jones Winn v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided May 23, 1979No. 77-1939PublishedCited by 36 opinions
1Opinion of the Court
CHARLES CLARK, Circuit Judge:
This case presents two unrelated questions of construction of the federal income tax law. The first requires that we interpret the term “passive investment income” in order to determine whether a taxpayer qualified for small business corporation, or “Subchapter S,” tax treatment under 26 U.S.C.A. § 1372 (Internal Revenue Code § 1372). The second involves examination of a claimed deduction for a charitable contribution under 26 U.S.C.A. § 170(c) (Internal Revenue Code § 170(c)).
The facts are basically undisputed. The taxpayers, E. H. Winn, Jr., and Betty Lee Jones…
2Cases cited12 opinions
- The SouthwarkSupreme Court of the United States · 1903
- United States v. SheaSupreme Court of the United States · 1894
- Morey v. RiddellDistrict Court, S.D. California · 1962
- Bramlette Building Corporation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- I. J. Marshall and Claribel Marshall v. Commissioner of Internal Revenue, Flora H. Miller v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1975
7 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Grunwald v. CommissionerUnited States Tax Court · 1986
- Consolidated Grain & Barge Company v. Marcona Conveyor Corporation, Marcona Sales, Inc. v. Consolidated Grain & Barge CompanyCourt of Appeals for the Fifth Circuit · 1983
- Estate of Camara v. CommissionerUnited States Tax Court · 1988
- John D. Crouch v. United StatesCourt of Appeals for the Tenth Circuit · 1982
- Bayou Steel Corp. v. National Union Fire Ins. Co.Court of Appeals for the Fifth Circuit · 2011
31 more not listed; retrieve them via the Exa API.