Legal Opinion

Bruce W. Hulbert v. Commissioner of Internal Revenue, Charles H. Edwards v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided November 22, 1955No. 11353, 11354PublishedCited by 26 opinions

1Opinion of the Court

SCHNACKENBERG, Circuit Judge.

Petitioners ask us to review1 the decisions of the Tax Court holding that they are liable for deficiencies in individual income tax for the taxable year 1946, arsing from their alleged receipt of $91,220.94 as ordinary income in the transaction hereinafter referred to.

Century Biscuit Company2 was a co-partnership consisting of Charles H. Edwards and his wife and Bruce W. Hulbert and his wife, each having a one fourth interest.

We now set forth the essential facts.3

Following protracted negotiations, Century, on March 26, 1946, entered into a written contract for the…

2Cases cited10 opinions

  1. Lucas v. EarlSupreme Court of the United States · 1930
  2. Harrison v. SchaffnerSupreme Court of the United States · 1941
  3. Heiner v. MellonSupreme Court of the United States · 1938
  4. Galt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1954
  5. Harriss v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944

5 more not listed; retrieve them via the Exa API.

3Cited by26 opinions

  1. United States v. BasyeSupreme Court of the United States · 1973
  2. 2 Lexington Ave. Corp. v. CommissionerUnited States Tax Court · 1956
  3. Victor Leff and Mary Leff, Husband and Wife v. Commissioner of Internal Revenue, George Sindeband v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
  4. F. C. Winters v. V. Y. Dallman, Collector of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
  5. Avery Brundage and Elizabeth D. Brundage v. United StatesCourt of Appeals for the Seventh Circuit · 1960

21 more not listed; retrieve them via the Exa API.

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