Legal Opinion

O'malley, Collector of Internal Revenue v. Ames

Court of Appeals for the Eighth Circuit

Decided June 16, 1952No. 14304_1PublishedCited by 57 opinions

1Opinion of the Court

GARDNER, Chief Judge.

This appeal is from a judgment in favor of appellee, the taxpayer, against appellant as Collector of ■ Internal Revenue in an action to recover the amount of a deficiency assessment levied by the Collector of Internal Revenue against appellee and paid by him under protest. We shall refer to the parties as they were designated in the trial court.

In 1943 plaintiff exchanged 180 shares of stock in Bankers Life Insurance Company of Nebraska for 18,000 trust certificates of a conceded value of $540,000. For each share of Bankers Life plaintiff received property worth $3,000.…

2Cases cited7 opinions

  1. Brooks-Scanlon Corp. v. United StatesSupreme Court of the United States · 1924
  2. Pendergrass v. New York Life Ins. Co.Court of Appeals for the Eighth Circuit · 1950
  3. Skelly Oil Co. v. HollowayCourt of Appeals for the Eighth Circuit · 1948
  4. Bonham v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1937
  5. TUNNEL RR v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1932

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3Cited by57 opinions

  1. Affiliated Ute Citizens of Utah v. United StatesSupreme Court of the United States · 1972
  2. Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  3. Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
  4. Riss v. CommissionerUnited States Tax Court · 1971
  5. Palmer v. CommissionerUnited States Tax Court · 1974

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