Legal Opinion
United States v. Harold W. Ivey and Mrs. Virginia Ivey, Harold W. Ivey and Mrs. Virginia Ivey v. United States
Court of Appeals for the Fifth Circuit
Decided October 6, 1961No. 18568_1PublishedCited by 21 opinions
1Opinion of the Court
WISDOM, Circuit Judge.
There are two unrelated issues in this tax litigation. The first concerns collapsible corporations. The government contends that in explaining collapsible corporations to the jury the trial judge erred in charging the jury as to the critical time when the requisite “view” to use the corporate device as a tax avoidance scheme must exist. The taxpayer finesses this issue. He argues that Section 341 of the Internal Revenue Code of 1954, 26 U.S.C.A. § 341, defining “collapsible corporations” is inapplicable when a taxpayer is entitled to capital gains treatment without…
2Cases cited13 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- 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
- C. D. Spangler and Veva C. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Paul v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
8 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
- Braunstein v. CommissionerSupreme Court of the United States · 1963
- Howard Wallace Barbee and Bobby Joe Manziel v. United StatesCourt of Appeals for the Fifth Circuit · 1968
- Isabel Collier Read, as of the Estate of Miles Collier, Deceased v. United StatesCourt of Appeals for the Fifth Circuit · 1963
- Nash v. CommissionerUnited States Tax Court · 1973
16 more not listed; retrieve them via the Exa API.