Legal Opinion
Tunnell v. United States
District Court, D. Delaware
Decided February 4, 1957No. Civ. A. No. 1809PublishedCited by 5 opinions
1Opinion of the Court
LEAHY, Chief Judge.
1. In 1951 plaintiffs’ tax on income totaled $22,534.66. One item represented the sale, on June 6, 1951, of a 50% partnership interest by James M. Tunnell, Jr., in the law firm of Tunnell and Tunnell.1 The amount received was $27,-500 less $3,307.13, the adjusted basis of fixed assets, or $24,192.87. The tax was computed and paid at the rates applicable to ordinary income.
On March 7, 1955, pursuant to 26 U.S. C. § 7422, plaintiffs filed with the Treasury Department a “claim for refund” in the amount of $7,297.28. Plaintiffs contended the item of partnership interest should…
2Cases cited47 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Harrison v. SchaffnerSupreme Court of the United States · 1941
42 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- James M. Tunnell, Jr., and Mildred S. Tunnell v. United StatesCourt of Appeals for the Third Circuit · 1958
- United States v. Barbara B. DonohoCourt of Appeals for the Eighth Circuit · 1960
- Donoho v. United StatesDistrict Court, D. Minnesota · 1958
- Safford v. United StatesDistrict Court, E.D. Wisconsin · 1963
- Ely v. CommissionerUnited States Tax Court · 1960