Legal Opinion
Jerrold L. Kingsley and June H. Kingsley v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided November 4, 1981No. 79-7662PublishedCited by 4 opinions
1Opinion of the Court
SKOPIL, Circuit Judge:
Taxpayers appeal from a decision of the Tax Court holding that they must pay tax on interest income imputed under I.R.C. § 483 on the deferred delivery of stock in a corporate reorganization. Gain on the shares transferred in the reorganization was not recognized under I.R.C. .§§ 354, 368. Taxpayers argue on appeal that section 483 may not be applied to a section 354 reorganization, that section 483 by its own terms does not apply to the present case, and that the Tax Court improperly calculated the interest on the deferred stock. We affirm. FACTS
There is no material…
2Cases cited10 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Bingler v. JohnsonSupreme Court of the United States · 1969
- June M. Carlberg, by Vida M. Frick, Guardian v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- Walter F. Vorbleski and Florence Vorbleski v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Hamrick v. CommissionerUnited States Tax Court · 1964
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3Cited by4 opinions
- Lester H. Krabbenhoft Anna Krabbenhoft v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1991
- Esther Lafargue v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Adair v. CommissionerUnited States Tax Court · 1985
- Lester H. Krabbenhoft Anna Krabbenhoft v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1991