Legal Opinion
Francis L. Rooney and Irene Rooney v. United States
Court of Appeals for the Ninth Circuit
Decided June 29, 1962No. 17313PublishedCited by 30 opinions
1Opinion of the Court
JAMES M. CARTER, District Judge.
This appeal raises two major issues: (1) the application of section 482 of the Internal Revenue Code of 1954 [26 U.S. C.A. § 482], which allows the Commissioner to reallocate expenses of the taxpayer, to the fact situation in this case, and (2) an interpretation of section 351 of the Internal Revenue Code of 1954 [26 U.S.C.A. § 351], which allows the taxpayer to transfer property to a corporation in exchange for stock, without recognition of gain or loss, and the effect that this section has on our controversy.
Appellants, husband and wife, are hop farmers. They…
2Cases cited9 opinions
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Jud Plumbing & Heating, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Asiatic Petroleum Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
- Central Cuba Sugar Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Central Cuba Sugar CoCourt of Appeals for the Second Circuit · 1952
- Simon J. Murphy Company and Social Research Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
4 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Spencer D. Stewart, Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Eli Lilly & Company and Subsidiaries, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1988
- Maxwell Hardware Company, a Corporation, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Ninth Circuit · 1965
- Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985
25 more not listed; retrieve them via the Exa API.