Legal Opinion
Joseph Lupowitz Sons, Inc. v. Commissioner
Court of Appeals for the Third Circuit
Decided May 22, 1974No. Nos. 73-1588 to 73-1590PublishedCited by 45 opinions
1Opinion of the Court
OPINION OF THE COURT
GARTH, Circuit Judge.
We have before us three appeals from the Tax Court presenting two different factual situations, but involving related parties and similar issues.
Appeal No. 73-1588 (“Penn Wynn”) involves transfers made by Joseph Lupowitz Sons, Inc. to Penn Wynn, Inc. The Commissioner contended and the Tax Court held that these transfers resulted in a debtor/creditor relationship between the two companies.
Appeal Nos. 73-1589 and 73-1590 (“Mansfield”) involved transfers made by Mansfield Homes, Inc. to Lupowitz. The Commissioner contends that the individual taxpayers…
2Cases cited22 opinions
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Rushing v. CommissionerUnited States Tax Court · 1969
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- W. B. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
17 more not listed; retrieve them via the Exa API.
3Cited by45 opinions
- Lester Crown v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1978
- Greenspun v. CommissionerUnited States Tax Court · 1979
- Crown v. CommissionerUnited States Tax Court · 1977
- Gilbert v. CommissionerUnited States Tax Court · 1980
- Strick Corporation, Appellant/cross-Appellee v. United States of America, Appellee/cross-AppellantCourt of Appeals for the Third Circuit · 1983
40 more not listed; retrieve them via the Exa API.