Legal Opinion

Vernon Edler, Jr. v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided March 6, 1984No. 82-7640PublishedCited by 14 opinions

1Opinion of the Court

COYLE, District Judge:

The Internal Revenue Service issued to Vernon Edler, Jr. (hereafter Edler) a Notice of Deficiency for the taxable year 1976 finding in pertinent part that Edler realized a constructive dividend in the amount of $283,500.00 resulting from the redemption of stock owned by his former spouse. 1 Edler filed a Petition with the United States Tax Court. The sole issue tried was whether Edler received dividend income when Edler Industries, Inc. (hereafter Industries) redeemed the stock owned by Edler’s former spouse. The matter was tried on fully stipulated facts.

Industries…

2Cases cited5 opinions

  1. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  2. Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
  3. William J. Sullivan and Georgia K. Sullivan v. United StatesCourt of Appeals for the Eighth Circuit · 1966
  4. Union Pacific Railroad Company, a Corporation v. Laverl Johnson and Joleen Johnson, Husband and Wife, and Pacific Fruit Express Company, a CorporationCourt of Appeals for the Ninth Circuit · 1957
  5. Stratton v. CommissionerUnited States Tax Court · 1969

3Cited by14 opinions

  1. Blatt v. CommissionerUnited States Tax Court · 1994
  2. Hayes v. CommissionerUnited States Tax Court · 1993
  3. Arnes v. CommissionerUnited States Tax Court · 1994
  4. Arnes v. CommissionerUnited States Tax Court · 1994
  5. Arnes v. CommissionerUnited States Tax Court · 1994

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