Legal Opinion

Waddell v. COMMISSIONER OF INTERNAL REVENUE

Court of Appeals for the Fifth Circuit

Decided March 13, 1939No. 8895PublishedCited by 12 opinions

1Opinion of the Court

HUTCHESON, Circuit Judge.

On the assumption that certain instalment obligations, resulting from the sale of mineral interests, were partnership properties, the Board 1 found that by the death of W. N. Waddell, one of the partners, the obligations, at least as to his interest in them, were, within Sec. 44(d) Revenue Act of 1932, 2 distributed, transmitted or otherwise disposed of, with a resulting taxable gain for that year of the unpaid instalments.

Petitioners are here vigorously controverting this conclusion. They urge upon us that the obligations as to which the tax was imposed, were not…

2Cases cited17 opinions

  1. Helvering v. New York Trust Co.Supreme Court of the United States · 1934
  2. Oliphant v. MarkhamTexas Supreme Court · 1891
  3. Martin v. DialTexas Commission of Appeals · 1933
  4. Altgelt, Administrator v. National BankTexas Supreme Court · 1904
  5. Moore v. SteeleTexas Supreme Court · 1887

12 more not listed; retrieve them via the Exa API.

3Cited by12 opinions

  1. Woody v. CommissionerUnited States Tax Court · 1952
  2. Crabb v. CommissionerCourt of Appeals for the Fifth Circuit · 1943
  3. Goldberg's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
  4. Bright v. United StatesDistrict Court, E.D. Pennsylvania · 1953
  5. Dixon v. CommissionerUnited States Tax Court · 1951

7 more not listed; retrieve them via the Exa API.

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