Legal Opinion
J. S. Biritz Construction Co. v. Commissioner of Internal Revenue, Joseph S. Biritz and Dorothy Biritz v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided December 12, 1967No. 18817_1PublishedCited by 42 opinions
1Opinion of the Court
FLOYD R. GIBSON, Circuit Judge.
This is a petition to review two decisions of the Tax Court, holding that a note taken by a sole stockholder from his corporation in exchange for some land represented a contribution to capital rather than a debt. The decisions concern a single issue and were consolidated for purpose of trial and for review.
The Tax Court in an opinion by Scott, J., sustained the determination of the Commissioner of Internal Revenue increasing the taxable income of petitioners, Joseph and Dorothy Biritz, for the calendar year 1960 by $15,290, as additional dividend income…
2Cases cited25 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Dobson v. CommissionerSupreme Court of the United States · 1944
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
20 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Litton Business Systems, Inc. v. CommissionerUnited States Tax Court · 1973
- A. R. Lantz Co., Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1970
- Haag v. CommissionerUnited States Tax Court · 1987
- In the Matter of Uneco, Inc., Bankrupt. United States of America v. Uneco, Inc.Court of Appeals for the Eighth Circuit · 1976
37 more not listed; retrieve them via the Exa API.