Legal Opinion
Samuel Katkin and Doris Katkin v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided January 26, 1978No. 77-1483PublishedCited by 12 opinions
1Opinion of the Court
LIVELY, Circuit Judge.
The question in this case is whether the receipt of stock in 1971 by shareholders of a corporation which was a party to a 1968 merger that qualified as a tax-free reorganization constituted a “deferred payment” within the meaning of section 483 of the Internal Revenue Code, 26 U.S.C. § 483. Section 483 provides in general for imputation of interest according to a statutory formula to any payment under a contract for the sale or exchange of property which constitutes part or all of the sales price and which is deferred for more than one year after the sale or exchange,…
2Cases cited6 opinions
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- June M. Carlberg, by Vida M. Frick, Guardian v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- Jeffers v. United StatesUnited States Court of Claims · 1977
- Benjamin and Alice Fox v. United StatesCourt of Appeals for the Third Circuit · 1975
- Sidney R. Solomon and Beatrice Solomon v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1977
1 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Gammill v. CommissionerUnited States Tax Court · 1980
- Walter F. Vorbleski and Florence Vorbleski v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Lester H. Krabbenhoft Anna Krabbenhoft v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1991
- Tennessee Baptist Children's Homes, Inc. And Dr. Evans B. Bowen, Cross-Appellants v. United States of America, Cross-AppelleeCourt of Appeals for the Sixth Circuit · 1986
- Jerrold L. Kingsley and June H. Kingsley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1981
7 more not listed; retrieve them via the Exa API.