Legal Opinion
Wheat v. United States
District Court, S.D. Texas
Decided January 18, 1973No. Civ. A. 70-H-786 to 70-H-789PublishedCited by 21 opinions
1Opinion of the Court
MEMORANDUM AND ORDER
CARL O. BUE, Jr., District Judge.
In these four consolidated actions the plaintiffs seek a refund of income taxes and assessed interest as a result of the allegedly erroneous disallowance of certain deductions for their pro rata share of the net operating loss of an electing small business corporation under Sub-chapter S of the Internal Revenue Code pursuant to 26 U.S.C. § 7422(a) and 26 U.S.C. § 1846. In a direct attack on the propriety of plaintiffs’ cause of action, the Government has moved for summary judgment pursuant to Rule 56, Fed.R.Civ.P.
To capsule the undisputed…
2Cases cited20 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Brunswick Corporation v. Harold VinebergCourt of Appeals for the Fifth Circuit · 1967
- Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1931
15 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Morris G. Underwood and Jackie Underwood, Individuals v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
- Underwood v. CommissionerUnited States Tax Court · 1975
- Estate of Leavitt v. CommissionerUnited States Tax Court · 1988
- Edward M. Selfe and Jane B. Selfe v. United StatesCourt of Appeals for the Eleventh Circuit · 1985
- Hitchins v. CommissionerUnited States Tax Court · 1994
16 more not listed; retrieve them via the Exa API.