Legal Opinion

Arnfeld v. United States

United States Court of Claims

Decided July 16, 1958No. 477-55PublishedCited by 27 opinions

1Opinion of the Court

JONES, Chief Judge.

Plaintiffs, executors of the estates of Andrew and Elsa Wineman, sue to recover income taxes and deficiency interest for the year 1951. The amount claimed is $25,494.25.

The issue presented for our determination is whether the increment realized by taxpayer Elsa Wineman upon the transfer of an annuity contract prior to its maturity constitutes ordinary income or capital gain.

The annuity contract in question was acquired by Andrew Wineman on January 6, 1933, and thereafter was assigned to his wife, Elsa Wineman, on January 11, 1933. Issued by the Penn Mutual Life Insurance…

2Cases cited11 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Commissioner v. TowerSupreme Court of the United States · 1946
  3. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  4. Hort v. CommissionerSupreme Court of the United States · 1941
  5. Bessie Lasky and Jesse L. Lasky v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956

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

3Cited by27 opinions

  1. Stanton v. CommissionerUnited States Tax Court · 1960
  2. Commissioner of Internal Revenue v. Percy W. Phillips and Betty R. Phillips (Husband and Wife)Court of Appeals for the Fourth Circuit · 1960
  3. Simon Jaglom and Marie Jaglom v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
  4. Ernest L. Wilkinson and Alice L. Wilkinson v. The United StatesUnited States Court of Claims · 1962
  5. Jones v. CommissionerUnited States Tax Court · 1962

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API