Legal Opinion

Pearson B. Garrett, Jr. v. Ellis Campbell, Jr., District Director of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided May 5, 1966No. 22269PublishedCited by 22 opinions

1Opinion of the Court

JOHN R. BROWN, Circuit Judge:

This appeal arises out of a jury verdict for the Government in Taxpayer’s refund suit. In April 1957 the Taxpayer 1 received 40,000 shares of stock in Quinta Corporation. In his 1957 tax return, however, Taxpayer reported no income from the receipt of this stock. The Commissioner determined a deficiency on the ground that the shares were oi dinary income when received in 1957 as payment for services rendered by Taxpayer. The Taxpayer’s suit for refund asserted that the shares were received in exchange for a capital asset which he had acquired in August 1956 and…

2Cases cited20 opinions

  1. Carter v. Atlanta & St. Andrews Bay Railway Co.Supreme Court of the United States · 1950
  2. Aetna Insurance Company v. PaddockCourt of Appeals for the Fifth Circuit · 1962
  3. Terminal R. Ass'n of St. Louis v. FitzjohnCourt of Appeals for the Eighth Circuit · 1948
  4. Clyde O. Williams v. National Surety CorporationCourt of Appeals for the Fifth Circuit · 1958
  5. Sam Hoover v. United StatesCourt of Appeals for the Fifth Circuit · 1966

15 more not listed; retrieve them via the Exa API.

3Cited by22 opinions

  1. Frank Coughlin, Padre Concrete Corporation, A. W. Van Cleave, Jr. And Allied Crushed Stone Company v. Capitol Cement Co.Court of Appeals for the Fifth Circuit · 1978
  2. Fed. Sec. L. Rep. P 96,189 First Virginia Bankshares v. Alan BensonCourt of Appeals for the First Circuit · 1977
  3. Fredonia Broadcasting Corporation, Inc. v. Rca CorporationCourt of Appeals for the Fifth Circuit · 1973
  4. Hobart Brothers Company v. Malcolm T. Gilliland, Inc.Court of Appeals for the Fifth Circuit · 1973
  5. Bobsee Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1969

17 more not listed; retrieve them via the Exa API.

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