Legal Opinion
Marvin E. Singleton, Jr. And Gertrude R. Singleton v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided March 16, 1978No. 75-4190PublishedCited by 4 opinions
1Opinion of the Court
TUTTLE, Circuit Judge:
This income tax dispute involves dividends paid to Singleton and his wife (hereinafter “taxpayer”) by Capital Southwest Corporation (CSW). The taxability of these payments is in turn dependent upon the character of payments made to CSW by a subsidiary, Capital Wire and Cable Corporation (CW). The Commissioner contends that a distribution of $803,750 by the subsidiary to its parent in 1965 was CSW’s part of a duly declared dividend of $1,000,000, distributed to stockholders of the subsidiary, including CSW and that since it was paid out of earnings and profits, it…
2Cases cited7 opinions
- Western Pac R.R. Corp. v. Western Pac. R. Co. Metzger v. Western Pac. R. Co.Court of Appeals for the Ninth Circuit · 1952
- Southwestern Life Insurance Company, Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Beneficial Corp. v. CommissionerUnited States Tax Court · 1952
- Dynamics Corporation of America (Formerly Claude Neon, Inc.) v. The United StatesUnited States Court of Claims · 1968
- John and Betty MacGuire v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
2 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Wolter Construction Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
- Singleton Et Ux. v. Commissioner of Internal RevenueSupreme Court of the United States · 1978
- Singleton Et Ux. v. Commissioner of Internal RevenueSupreme Court of the United States · 1978
- Singleton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1978