Legal Opinion

Jacobs v. United States

District Court, S.D. Ohio

Decided September 14, 1966No. Civ. A. 5454PublishedCited by 24 opinions

1Opinion of the Court

MEMORANDUM OPINION

JOHN W. PECK, District Judge.

In this action the plaintiff (hereinafter usually “taxpayer”) seeks to recover deficiency assessments paid by him as income tax for the calendar years 1959 and 1960. Jurisdiction under Internal Revenue Code, Sections 6532, 7422(a), 28 U.S.C., Section 1346(a) is conceded.

The extensive and helpful stipulations agreed to by counsel establish the factual pattern. Taxpayer, his relatives, and one of his employees owned the Triangle Paper Bag Manufacturing Company (hereinafter “Triangle”) a Kentucky corporation. In 1959 Triangle sold its assets and was…

2Cases cited3 opinions

  1. Granite Trust Company v. United StatesCourt of Appeals for the First Circuit · 1956
  2. Cook v. CommissionerUnited States Tax Court · 1945
  3. S. M. Friedman and Esther G. Friedman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1965

3Cited by24 opinions

  1. Rushing v. CommissionerUnited States Tax Court · 1969
  2. W. B. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
  3. Edwin W. Hudspeth and Maxine G. Hudspeth v. United StatesCourt of Appeals for the Eighth Circuit · 1972
  4. Walter R. Carrington and Ada Raye Carrington v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
  5. John P. Kinsey and Edith B. Kinsey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973

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