Legal Opinion

R. M. Edwards and Dorothy Edwards v. Commissioner of Internal Revenue, Loyd W. Disler and Joy Disler v. Commissioner of Internal Revenue

Court of Appeals for the Tenth Circuit

Decided October 20, 1969No. 44-68-45-68_1PublishedCited by 20 opinions

1Opinion of the Court

LEWIS, Circuit Judge.

This joint petition brought by taxpayers 1 pursuant to 26 U.S.C. § 7482 seeks review of a decision of the Tax Court of the United States, 50 T.C. 220, wherein that court, with five judges dissenting, determined that certain income received by petitioning taxpayers during the years 1962, 1963, and 1964 should be taxed as ordinary dividend income pursuant to 26 U.S.C. §§ 301 and 316, rather than as capital gains within the purview of 26 U.S.C. § 1232. A deficiency in the sum of $21,058.24 was assessed against petitioners Edwards and the sum of $19,821.00 against petitioners…

2Cases cited7 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  3. Nassau Lens Co., Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Harry Pildes and Sarah PildesCourt of Appeals for the Second Circuit · 1962
  4. J. S. Biritz Construction Co. v. Commissioner of Internal Revenue, Joseph S. Biritz and Dorothy Biritz v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1967
  5. Jewell Ridge Coal Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963

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

3Cited by20 opinions

  1. BOARD OF TRUSTEES, LARAMIE CTY SCH. D. NO. 1 v. SpiegelWyoming Supreme Court · 1976
  2. Waterman Steamship Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
  3. J. E. Casner and Una Casner v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
  4. Lewis and Taylor, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
  5. Thomas H. Hutton and Betty Hutton v. United StatesCourt of Appeals for the Sixth Circuit · 1974

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

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