Legal Opinion
Busse v. United States
United States Court of Claims
Decided October 20, 1976No. 224-73PublishedCited by 4 opinions
1Opinion of the CourtDureee, Senior Judge
In this tax refund action, plaintiff, an individual taxpayer, challenges the Internal Revenue Service’s [IRS or Service] determination that the imputed interest provisions of the Internal Revenue Code (26 U.S.C. § 488) apply to the payments plaintiff received from the sale of her interest in a patent. Because of the specificity with which the Code section applies to the taxpayer, the Service must prevail on its determination.
The parties’ stipulation provides the following factual backdrop to the instant controversy. In 1962, plaintiff, as widow of Gilbert Busse, inherited Gilbert’s undivided…
2Cases cited12 opinions
- Montclair v. RamsdellSupreme Court of the United States · 1883
- Commissioner v. BrownSupreme Court of the United States · 1965
- Hellmich v. HellmanSupreme Court of the United States · 1928
- Curtis T. Busse and Myrtle Busse v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
- Max A. Burde and Berthe C. Burde v. Commissioner of Internal Revenue, Bernard Weiss and Peggy S. Weiss v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
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3Cited by4 opinions
- Hooker Chemicals & Plastics Corp. v. United StatesUnited States Court of Claims · 1979
- Ransburg Corp. v. CommissionerUnited States Tax Court · 1979
- Ransburg Corp. v. CommissionerUnited States Tax Court · 1979
- Ransburg Corporation and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980