Legal Opinion
George K. Heebner, Jr. And Ruth S. Heebner v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided July 29, 1960No. 13173PublishedCited by 25 opinions
1Opinion of the Court
STALEY, Circuit Judge.
This taxpayer’s petition for review of a decision of the Tax Court primarily poses the question whether the profit realized on the disposition of certain property was properly treated by the Tax Court as ordinary income rather than capital gain. Two subsidiary issues were also raised in the Tax Court, one relating to an expense deduction and the other to a constructive dividend. The former issue was withdrawn on appeal and the latter need be considered only if it is determined that the Tax Court erred in holding that the profit realized was ordinary income.
The facts may…
2Cases cited4 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- The Pennroad Corporation and Affiliated Companies v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- E. Aldine Lakin, J. Lee Mullendore and Cecil M. Mullendore v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
3Cited by25 opinions
- Missouri Pacific Railroad Company v. Clyde AustinCourt of Appeals for the Fifth Circuit · 1961
- Pleasant Summit Land Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1988
- Joseph B. And Josephine L. Simon v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Joseph B. And Josephine L. SimonCourt of Appeals for the Third Circuit · 1961
- Todd Tibbals and Helen A. Tibbals v. The United StatesUnited States Court of Claims · 1966
- Around the World Shoppers Club v. United StatesCourt of Appeals for the Third Circuit · 1962
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