Legal Opinion

Russell Mann and Vivian Mann v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided August 27, 1973No. 72-1761PublishedCited by 31 opinions

1Opinion of the Court

VAN OOSTERHOUT, Senior Circuit Judge.

This is a timely appeal by taxpayer Russell Mann 1 from the decision of the Tax Court 2 sustaining the Commissioner’s determination of a deficiency of $9,957.95 in income tax for 1966. The deficiency arose out of the disallowance of a deduction for payment of $20,731.00 made to Keith Wilson Hatchery, Inc. (Hatchery), on December 31, 1966, for feed to be delivered and used in 1967 in taxpayer’s feeder pig operation. Jurisdiction is conferred by § 7482 I.R.C. 1954.

The relevant facts as found by the Tax Court may be thus summarized:

Taxpayer is a real estate…

2Cases cited22 opinions

  1. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  2. Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
  3. R D. And Ida M. Cravens v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1959
  4. Cohn v. FisherNew Jersey Superior Court Appellate Division · 1972
  5. University Properties, Inc. v. CommissionerUnited States Tax Court · 1966

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

3Cited by31 opinions

  1. E. Keith Owens v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
  2. Rubnitz v. CommissionerUnited States Tax Court · 1977
  3. Packard v. CommissionerUnited States Tax Court · 1985
  4. Keller v. CommissionerUnited States Tax Court · 1982
  5. Martin J. And Margaret M. Zaninovich and Vincent M. And Dorothy F. Zaninovich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980

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

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