Legal Opinion
Commissioner of Internal Revenue v. Ralph J. Solow and Celia O. Solow
Court of Appeals for the Second Circuit
Decided June 9, 1964No. 28603_1PublishedCited by 10 opinions
1Opinion of the Court
WATERMAN, Circuit Judge:
The question raised by this petition is whether profits realized in 1950 from the sale of certain corporate stock should be taxed at capital gains rates, or whether Section 117(m) of the Internal Revenue Code of 1939, as amended by Section 212 of the Revenue Act of 1950, 64 Stat. 906, 1 in force at the time of the relevant sale and which prescribes special tax treatment for income realized through the use of the device of a “collapsible” corporation, requires that the profits be taxed as ordinary income. The Tax Court determined that capital gains treatment was in…
2Cases cited7 opinions
- Shirley A. Ber v. Anthony J. Celebrezze, Secretary of Health, Education and WelfareCourt of Appeals for the Second Circuit · 1964
- Arthur Glickman Herman Glickman and Ruth Glickman and Aaron Glickmand and Freda Glickman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Braunstein v. CommissionerSupreme Court of the United States · 1963
- Temkin v. CommissionerUnited States Tax Court · 1961
- Riley v. CommissionerUnited States Tax Court · 1961
2 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Todd Tibbals and Helen A. Tibbals v. The United StatesUnited States Court of Claims · 1966
- Commissioner of Internal Revenue v. Sylvester J. Lowery and Rosemary P. LoweryCourt of Appeals for the Third Circuit · 1964
- Crowe v. CommissionerUnited States Tax Court · 1974
- Glenn C. Bailey, Lillian S. Bailey, and Inez N. Bailey v. United StatesCourt of Appeals for the Ninth Circuit · 1966
- Barbara Coal Co. v. CommissionerUnited States Tax Court · 1987
5 more not listed; retrieve them via the Exa API.