Legal Opinion

Daniel Jacobs v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided February 2, 1983No. 81-1376PublishedCited by 6 opinions

1Per curiam

This is an appeal by Daniel Jacobs (Jacobs) and Paul Schurger (Schurger) (collectively referred to infra as “the taxpayers”) from a decision of the United States Tax Court, entered on February 25, 1981, which upheld determinations by the Commissioner of Internal Revenue (IRS, or the Service) that deficiencies existed in the appellants’ 1975 federal personal income tax returns as the result of a constructive dividend. Margaret Jacobs and Ann Schurger are listed here as appellants solely by virtue of having filed joint returns with their husbands.

All the facts but the ultimate fact at issue are…

2Cases cited9 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Boehm v. CommissionerSupreme Court of the United States · 1945
  3. E. Keith Owens v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
  4. Stephens v. CommissionerUnited States Tax Court · 1973
  5. Ohio Teamsters Educational and Safety Training Trust Fund v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1982

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3Cited by6 opinions

  1. Estate of Arthur Chase Shafer, Deceased, Chase Shafer, Co-Executor, and Resor Shafer, Co-Executor v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
  2. Hayes v. CommissionerUnited States Tax Court · 1993
  3. Estate of Antoinette P. Mitchell, the Farmers National Bank & Trust Company of Ashtabula v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
  4. Gerson v. CommissionerUnited States Tax Court · 1989
  5. Hayes v. CommissionerUnited States Tax Court · 1993

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