Legal Opinion
Fritz Thompson and Dora M. Thompson v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided September 26, 1963No. 20074_1PublishedCited by 59 opinions
1Opinion of the Court
JOHN R. BROWN, Circuit Judge.
On Taxpayer’s1 appeal from an adverse judgment of the Tax Court, two questions are presented. The first is the old, familiar, recurring, vexing and ofttimes elusive 2 problem of the treatment of proceeds of sales of subdivided lots as capital gains or ordinary income. Second, a completely novel problem never before presented and unlikely ever to arise again has to do with the treatment of a parity price support loan as income in the year received even though the loan is redeemed prior to the expiration of the tax year, and the wheat is not sold by the…
2Cases cited16 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
- Arthur W. Smith and Mrs. Arthur W. Smith v. Charles H. Dunn, Formerly Acting Collector of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- United States v. Charles G. Eidson, Jr.Court of Appeals for the Fifth Circuit · 1962
- Josef C. Patchen and Aleyne E. Patchen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
11 more not listed; retrieve them via the Exa API.
3Cited by59 opinions
- United States v. Ada Belle Winthrop, Individually and as Under the Will of Guy L. Winthrop, DeceasedCourt of Appeals for the Fifth Circuit · 1969
- Biedenharn Realty Co. v. United StatesCourt of Appeals for the Fifth Circuit · 1976
- Suburban Realty Company v. United StatesCourt of Appeals for the Fifth Circuit · 1980
- Byram v. United StatesCourt of Appeals for the Fifth Circuit · 1983
- Buono v. CommissionerUnited States Tax Court · 1980
54 more not listed; retrieve them via the Exa API.