Legal Opinion
Particelli v. Commissioner of Internal Revenue. Particelli's Estate v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 5, 1954No. 13503_1PublishedCited by 24 opinions
1Opinion of the Court
ORR, Circuit Judge.
Petitioner Giulio Particelli, 1 having been engaged in the business of operating a winery in the state of California for some years, decided to dispose of the winery business. Prior to making the decision to sell, petitioner had been ap proached by a buyer of wine, one John Dumbra, a representative of Tiara Products Company, Inc., hereafter Tiara, who made an offer to buy three or four cars of wine. Because of the then existing O.P.A. price ceilings no profit could be realized from the sale of the wine. Petitioner made a counter offer to sell the wine and winery for the sum…
2Cases cited6 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. TowerSupreme Court of the United States · 1946
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Sinclair v. United StatesSupreme Court of the United States · 1929
- Thompson v. Baltimore & OR Co.Court of Appeals for the Eighth Circuit · 1946
1 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Schulz v. CommissionerCourt of Appeals for the Ninth Circuit · 1961
- Martin Ice Cream Co. v. Comm'rUnited States Tax Court · 1998
- Redwing Carriers, Inc. v. TomlinsonCourt of Appeals for the Fifth Circuit · 1968
- Paul W. Trousdale v. Commissioner of Internal Revenue, Marguerite R. Trousdale v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Ray H. Schulz and Doris L. Schulz v. Commissioner of Internal Revenue, John W. Schulz and Lucille Schulz v. Commissioner of Internal Revenue, Melvin F. Klagues and Pauline Klagues v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Stanley C. Landen and Victoria M. LandenCourt of Appeals for the Ninth Circuit · 1961
19 more not listed; retrieve them via the Exa API.