Legal Opinion
August v. Commissioner
Court of Appeals for the Third Circuit
Decided June 12, 1959No. Nos. 12825-12829PublishedCited by 15 opinions
1Opinion of the Court
STALEY, Circuit Judge.
We are presented on this appeal with the not uncommon question whether the gain realized by the shareholders of a corporation upon a partial redemption of their stock is taxable as long-term capital gain, or is taxable as ordinary income under the provisions of Section 117(m) of the Internal Revenue Code of 1939, 26 U.S.C.A. (I.R.C.1939) § 117(m), the collapsible corporation section.
The facts as found by the Tax Court were stipulated in part. This proceeding, in which five cases have been consolidated, involves alleged deficiencies in income tax for the taxable year…
2Cases cited7 opinions
- Raymond G. Burge and Kathleen E. Burge v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- 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
- J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Philber Equipment Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
- Curtis Company (Formerly Curtis Engineering Company) v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
2 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Estate of Maria M. Coxe Skinner, Deceased, Neil McFee Skinner and Girard Trust Corn Exchange Bank, Executors v. United StatesCourt of Appeals for the Third Circuit · 1963
- C. D. Spangler and Veva C. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Sidney v. CommissionerCourt of Appeals for the Second Circuit · 1960
- Joseph B. And Josephine L. Simon v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Joseph B. And Josephine L. SimonCourt of Appeals for the Third Circuit · 1961
- Jacobson v. CommissionerCourt of Appeals for the Third Circuit · 1960
10 more not listed; retrieve them via the Exa API.