Legal Opinion
Gene L. Kreider and Estate of Berniece L. Kreider, Deceased, Gene L. Kreider v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided May 28, 1985No. 84-2070PublishedCited by 23 opinions
1Opinion of the Court
FLAUM, Circuit Judge.
Petitioner-appellant Gene L. Kreider, individually and as executor of the estate of his deceased wife, Berniece L. Kreider, appeals from a decision of the United States Tax Court characterizing a $631,383.80 payment that the Kreiders received in 1977 upon the sale of their trucking company. The issues presented on appeal are: (1) whether the payment in question constituted consideration for the Kreiders’ stock in the company, consideration for a covenant not to compete, or compensation for personal services; and (2) if the payment was consideration for a covenant not to…
2Cases cited17 opinions
- Hormel v. HelveringSupreme Court of the United States · 1941
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
12 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Gehl Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Muskat v. United StatesCourt of Appeals for the First Circuit · 2009
- Illinois Power Co. v. CommissionerUnited States Tax Court · 1986
- Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, and Naomi Kanter v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2003
- Berger v. CommissionerUnited States Tax Court · 1996
18 more not listed; retrieve them via the Exa API.