Legal Opinion
H. N. Watson, Jr., and Wife, Shirley Watson v. Commissioner of Internal Revenue Service
Court of Appeals for the Fifth Circuit
Decided March 14, 1980No. 78-1770PublishedCited by 15 opinions
1Opinion of the Court
SAM D. JOHNSON, Circuit Judge:
H. N. (Sonny) and Shirley Watson are taxpayers utilizing the cash receipts and disbursements method of accounting. In November, 1973 they sold a number of bales of cotton pursuant to an arrangement called a deferred payment agreement. In return they received an irrevocable banker’s letter of credit in the amount of $42,146.51. The bank’s letter of credit guaranteed it would accept and honor this instrument in January, 1974. On January 10, 1974, Sonny Watson went to the bank and exchanged the letter of credit for a check for the face value of the instrument. The…
2Cases cited7 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Commissioner v. First Security Bank of Utah, N. A.Supreme Court of the United States · 1972
- Estate of Sam E. Broadhead, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Cowden v. CommissionerCourt of Appeals for the Fifth Circuit · 1961
2 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- UFE, Inc. v. CommissionerUnited States Tax Court · 1989
- John E. Reed v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1983
- Willamette Indus. v. CommissionerUnited States Tax Court · 1989
- R. Paul Sprague and Mary G. Sprague v. United StatesCourt of Appeals for the Tenth Circuit · 1980
- Piggy Bank Stations, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1985
10 more not listed; retrieve them via the Exa API.