Legal Opinion

Wiseman v. United States

District Court, D. Maine

Decided August 4, 1966No. Civ. No. 8-198PublishedCited by 6 opinions

1Opinion of the Court

OPINION AND ORDER OF THE COURT

GIGNOUX, District Judge.

This is an action for refund of $92,-302.50 federal incomes taxes for the year 1961, plus assessed interest in the amount of $16,532.25, paid by plaintiff under a deficiency assessment of the Commissioner of Internal Revenue.1 The case presents the question of whether the transfer of plaintiff’s stock in one of two brother-sister corporations owned by him, in exchange for the creation of an indebtedness to plaintiff on the books of the other corporation, gave rise to a corporate distribution “essentially equivalent to a dividend” within…

2Cases cited25 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Corliss v. BowersSupreme Court of the United States · 1930
  3. Gray v. PowellSupreme Court of the United States · 1941
  4. Bazley v. CommissionerSupreme Court of the United States · 1947
  5. Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947

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3Cited by6 opinions

  1. Mray A. Maher and Rose M. Maher v. Commissioner of Internal Revenue, Ray A. Maher, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1972
  2. Haserot v. CommissionerUnited States Tax Court · 1966
  3. John M. Wiseman v. United StatesCourt of Appeals for the First Circuit · 1967
  4. Gunther v. CommissionerUnited States Tax Court · 1989
  5. Gunther v. CommissionerUnited States Tax Court · 1989

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