Legal Opinion
John H. Rickey and Lorraine C. Rickey v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided July 19, 1974No. 26-775PublishedCited by 15 opinions
1Opinion of the Court
OPINION
KOELSCH, Circuit Judge:
John H. Rickey (Taxpayer) and Lorraine C. Rickey1 2appeal from a decision of the Tax Court3 determining a deficiency in income taxes for the tax year 1962. Our jurisdiction is founded on Section 7482 of the Internal Revenue Code of 1954, 26 U.S.C. § 7482.
Two distinct issues are presented for review. The first is whether Taxpayer received over 30 per cent of the selling price of stock in two corporations in the year of sale, thereby precluding reporting of the gain under the installment method provided by Code Section 453, 26 U.S.C. § 453. See 26 U.S.C. § 453(b)…
2Cases cited13 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- W. B. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Pierre Godart and Suzanne Godart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
8 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Malinowski v. CommissionerUnited States Tax Court · 1979
- United States v. James C. Russell, Earhl R. Schooff, and Lawrence M. RicheyCourt of Appeals for the Ninth Circuit · 1986
- West Shore Fuel, Inc. v. United States of America, Ruth A. Kolb v. United StatesCourt of Appeals for the Second Circuit · 1979
- A. Ross Winans Grantor Trust v. CommissionerUnited States Tax Court · 1989
- Connell v. CommissionerUnited States Tax Court · 1981
10 more not listed; retrieve them via the Exa API.