Legal Opinion
Lovell and Hart, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided March 2, 1972No. 71-1455PublishedCited by 44 opinions
1Per curiam
We consider an appeal from a decision of the Tax Court upholding the Commissioner’s determination that appellant “constructively received” certain notes issued to its shareholders in exchange for property transferred by appellant to a corporation it controlled. The facts are explicated in the opinion of the Tax Court, reported at 39 P-H Tax Ct.Mem. ¶ 70,335 (1970), and we affirm on the basis of that opinion for the reasons set forth herein.
The Commissioner grounded his deficiency assessment upon § 351(b) of the Internal Revenue Code. 1 He contended that, together with cash and equipment…
2Cases cited4 opinions
- Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Thomas W. Banks v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Robert C. Hoffman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Commissioner of Internal Revenue v. H. Halpine Smith and George K. Yetter (Mrs. Addie Small Smith, as of the Estate of H. Halpine Smith, Substituted for H. Halpine Smith, Deceased), Berlin Griffin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960
3Cited by44 opinions
- Palmer v. CommissionerUnited States Tax Court · 1974
- In Re Gary Louis Gardner, Debtor. Jeffrey D. Stamper, of the Estate of Gary Louis Gardner v. United StatesCourt of Appeals for the Sixth Circuit · 2004
- Ronald L. Lerch and Dalene Lerch v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 1989
- Walter Demkowicz and Dorothy Demkowicz v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1977
- Guilio J. Conti and Edith Conti v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1994
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