Legal Opinion
Cleveland v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided August 10, 1964No. Nos. 14511-14512PublishedCited by 2 opinions
1Opinion of the Court
WILLIAM F. SMITH, Circuit Judge.
These cases are before the court on petitions to review a decision of the Tax Court, 39 T.C. 657. The question for de-. cisión is whether the Tax Court erred in its determination that four disbursements of corporate funds, made in connection with the redemption of stock, “were not liquidating distributions” within the meaning of §§ 115(c) and (i) of the Internal Revenue Code of 1939, 26 U.S.C.A., I>ut were “instead * * * essentially equivalent to [dividends] within the meaning of” §§ 115(a) and *474(g) of the Code. The determination is challenged as clearly…
2Cases cited10 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Boyle v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
- Elizabeth N. B. Ferro v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957
- United States v. John H. FewellCourt of Appeals for the Fifth Circuit · 1958
- Calhoon v. HarveySupreme Court of the United States · 1964
5 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Davis v. United StatesDistrict Court, W.D. Pennsylvania · 1967
- Robert W. Cleveland and Anita H. Cleveland v. Commissioner of Internal Revenue, Royal E. Cleveland and Alvina D. Cleveland v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1964