Legal Opinion
Wilson v. United States
District Court, E.D. Missouri
Decided April 6, 1967No. Nos. S 66 C 44, 66 C 50, 66 C 65, 66 C 76PublishedCited by 2 opinions
1Opinion of the Court
MEMORANDUM
MEREDITH, District Judge.
This Court has jurisdiction under Title 28, U.S.C. § 1346(a), after a denial by the Internal Revenue Service of timely claims for refund made by plaintiffs.
The parties have stipulated as to the following facts: On or about August 25, 1959, the Killion-Rone-Wilson Gin Company, a partnership, was incorporated under the laws of Missouri. The partnership transferred its assets to the corporation in exchange for corporate stock, and the shareholders of the stock were and are the former partners (although not in equal shares). The corporation commenced business on…
2Cases cited9 opinions
- Haggar Co. v. Helvering, Com'r of Internal RevenueSupreme Court of the United States · 1940
- J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
- Charles Leich and Company v. The United StatesUnited States Court of Claims · 1964
- Lucas v. Sterling Oil & Gas Co.Court of Appeals for the Sixth Circuit · 1933
- J. E. Riley Inv. Co. v. CommissionerCourt of Appeals for the Ninth Circuit · 1940
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3Cited by2 opinions
- Frank Miskovsky v. United StatesCourt of Appeals for the Third Circuit · 1969
- Bmw (Us) Holding Corporation and Subsidiaries v. United StatesUnited States Court of Federal Claims · 2026