Legal Opinion
Boyd Gudgel and Geraldine Gudgel v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided December 28, 1959No. 13778_1PublishedCited by 12 opinions
1Opinion of the Court
SIMONS, Circuit Judge.
The petitioners, husband and wife, were dairy farmers. The principal issue in the case is whether, in subdividing their farm and selling lots therein, during the tax years 1951, 1952, and 1953, at a profit, they should have been permitted to return such profit in their income tax returns as capital gains or whether they were required to return it as ordinary income. The Commissioner asserts the profits constituted ordinary income and the Tax Court so held. The petitioners challenge that determination.
There is no dispute about the eviden-tiary facts. Most of them were…
2Cases cited19 opinions
- Commissioner v. AckerSupreme Court of the United States · 1959
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
- Arthur W. Smith and Mrs. Arthur W. Smith v. Charles H. Dunn, Formerly Acting Collector of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- Hycon Manufacturing Company v. H. Koch & Sons, a Partnership Consisting of M. P. Koch, W. L. Koch, H. M. Koch and R. Koch AbelCourt of Appeals for the Ninth Circuit · 1955
- Central Ry. Signal Co. v. LongdenCourt of Appeals for the Seventh Circuit · 1952
14 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Raymond Bauschard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1960
- United States Steel Corporation v. Barbara J. Fuhrman, Administratrix of the Estate of Arthur J. Fuhrman, DeceasedCourt of Appeals for the Sixth Circuit · 1969
- American State Bank, a Wisconsin Banking Corporation v. United States of America, (Two Cases)Court of Appeals for the Seventh Circuit · 1960
- Lester R. Ackerman and Wife, Edna Del Ackerman v. United StatesCourt of Appeals for the Fifth Circuit · 1964
- Commissioner of Internal Revenue v. Spermacet Whaling & Shipping Co., S/ACourt of Appeals for the Sixth Circuit · 1960
7 more not listed; retrieve them via the Exa API.