Legal Opinion

Felland v. Wilkinson

District Court, W.D. Wisconsin

Decided November 22, 1928No. 80-GPublishedCited by 8 opinions

1Opinion of the CourtLuse, District Judge

(after stating the facts as above). The bill discloses that prior to its dissolution the Stoughton Lumber Association was careful to have its 1919 business examined by a field man of the Internal Revenue Department to determine the amount of income tax for which the association might be liable, apparently with a view to avoiding the very difficulty which now presents itself, and that fact naturally enlists the sympathy of a court of equity but is deemed insufficient to constitute one of those exceptional cases which would make section 3224, Rev. St. (26 USCA § 154), inapplicable to a tax…

2Cases cited8 opinions

  1. Hill v. WallaceSupreme Court of the United States · 1922
  2. Lipke v. LedererSupreme Court of the United States · 1922
  3. Dodge v. OsbornSupreme Court of the United States · 1916
  4. Graham v. Du PontSupreme Court of the United States · 1923
  5. Bailey, Collector of Internal Revenue v. GeorgeSupreme Court of the United States · 1922

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3Cited by8 opinions

  1. Shelton v. Gill, Collector of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
  2. Phillips v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Trinacia Real Estate Co. v. ClarkeDistrict Court, N.D. New York · 1929
  4. McKowen v. Internal Revenue ServiceCourt of Appeals for the Tenth Circuit · 2004
  5. Baldassari v. United StatesCalifornia Court of Appeal · 1978

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