Legal Opinion

Stinnett's Pontiac Service, Inc., Richard W. Stinnett and Gay P. Stinnett v. Commissioner of Internal Revenue Service

Court of Appeals for the Eleventh Circuit

Decided April 20, 1984No. 82-6172PublishedCited by 62 opinions

1Opinion of the Court

HATCHETT, Circuit Judge:

In this case, we review the Tax Court’s holdings regarding the tax consequences of transactions involving two corporations and their common shareholder, the taxpayer, i We affirm.

Facts

Richard W. Stinnett is president of Pontiac, an automobile dealership, and he owns 74% of the stock in the company. 1 In the early 1960’s, Pontiac established a qualified profit sharing plan for its employees. Pontiac would calculate its year-end profit, and, if such profit exceeded $25,000, Pontiac would transfer 15% of the compensation paid to each employee-member to the plan. On or…

2Cases cited15 opinions

  1. Eckert v. BurnetSupreme Court of the United States · 1931
  2. Helvering v. PriceSupreme Court of the United States · 1940
  3. Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
  4. Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
  5. Charles A. Sammons, Individually, and Estate of Rosine S. Sammons, Deceased, Charles A. Sammons, Independent v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973

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3Cited by62 opinions

  1. Roth Steel Tube Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
  2. Segel v. CommissionerUnited States Tax Court · 1987
  3. Sender v. Bronze Group, LTD.Court of Appeals for the Tenth Circuit · 2004
  4. In Re James A. Lane, Bankrupt. Frances B. Lane and James M. Gaines, as Trustee of the Bankrupt Estate of James A. Lane v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
  5. In Re Cold Harbor Associates, L.P.United States Bankruptcy Court, E.D. Virginia · 1997

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