Legal Opinion
Billy E. Arnwine and Shirley S. Arnwine v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided January 31, 1983No. 81-4384PublishedCited by 11 opinions
1Opinion of the Court
RANDALL, Circuit Judge:
This case concerns the federal income tax consequences of loosely defined relationships among a West Texas cotton farmer anxious to shift his liability for federal income taxes on the proceeds of the sale of part of his 1973 cotton crop to 1974, the purchasers of his 1973 crop and a cotton gin anxious to be of service to all concerned. The Tax Court held that the proceeds were not taxable in 1973, finding that the cotton gin was acting as the agent of the purchasers, rather than the farmer, when payment for the cotton was made to the gin in 1973 and that the farmer did…
2Cases cited9 opinions
- Rourke v. GarzaTexas Supreme Court · 1975
- Helvering v. OwensSupreme Court of the United States · 1939
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Amend v. CommissionerUnited States Tax Court · 1949
- Schniers v. CommissionerUnited States Tax Court · 1977
4 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- John E. Reed v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1983
- United States v. RoushCourt of Appeals for the Fifth Circuit · 2006
- Keith Scherbart Janet Scherbart v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2006
- Bosamia v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Fifth Circuit · 2011
- Dorothy Olster v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1985
6 more not listed; retrieve them via the Exa API.