Legal Opinion

Hugh N. Mills and Jane W. Mills v. Commissioner of Internal Revenue

Court of Appeals for the Fourth Circuit

Decided September 3, 1968No. 11825_1PublishedCited by 49 opinions

1Opinion of the Court

BUTZNER, Circuit Judge:

Hugh N. Mills and Jane W. Mills 1 seek review of a decision of the tax court which found a deficiency in their 1961 income tax. 2 Two issues are involved. The first is whether the tax court correctly held that the taxpayer realized ordinary income, and not long-term capital gain, on the sale of stock options and stock. The second issue is whether $1,450 of unexplained bank deposits should be included in the taxpayer’s income. On both issues we affirm the tax court’s decision for the commissioner.

I

The taxpayer organized Mountaineer Fire & Casualty Insurance Company in…

2Cases cited16 opinions

  1. Helvering v. TaylorSupreme Court of the United States · 1935
  2. Helvering v. GowranSupreme Court of the United States · 1937
  3. Commissioner v. LoBueSupreme Court of the United States · 1956
  4. Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
  5. Commissioner v. SmithSupreme Court of the United States · 1945

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3Cited by49 opinions

  1. Estate of Mason v. CommissionerUnited States Tax Court · 1975
  2. Estate of Horvath v. CommissionerUnited States Tax Court · 1973
  3. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  4. Mary Ruark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
  5. Pagel, Inc. v. CommissionerUnited States Tax Court · 1988

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

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