Legal Opinion
Caruth v. United States
District Court, N.D. Texas
Decided October 20, 1987No. Civ. A. 3-84-0877-RPublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM OPINION
BUCHMEYER, District Judge.
This is an income tax case. It involves such exotic tax concepts as the “assignment of income” doctrine, the “economic realities” test, the “step-transaction” analysis, the business purpose requirement, and even an overworked horticultural metaphor. 1
The plaintiffs are W.W. and Mabel Caruth. In 1978, they were majority stockholders in a closely held corporation, North Park Inn, and they were the sole stockholders of a separate company, the Caruth Corporation. On May 8, 1978, North Park declared a dividend of $1,500 per share— which was payable on…
2Cases cited54 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Gregory v. HelveringSupreme Court of the United States · 1935
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
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3Cited by3 opinions
- Estate of Robert G. Kluener, Donald E. Hathaway, Co-Executor, Charlotte J. Kluener v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1998
- Caruth Corporation, W.W. And Mable P. Caruth v. United StatesCourt of Appeals for the Fifth Circuit · 1989
- Estate of Robert G. Kluener, Donald E. Hathaway, Co-Executor, Charlotte J. Kluener v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1998