Legal Opinion
Raymond J. Paige and Patricia C. Paige, His Wife v. United States
Court of Appeals for the Ninth Circuit
Decided August 17, 1978No. 75-2669PublishedCited by 1 opinion
1Opinion of the Court
SKOPIL, District Judge:
Plaintiff-taxpayers appeal from the denial of their claim for a tax refund. The issue involved is whether taxpayers’ corporation qualified for the subchapter S election provided in 26 U.S.C. § 1371 (1954). 1 We hold that it did not. We affirm.
Tackmer made the subchapter S election in 1965. The government now contends that Tackmer Corporation had more than one class of stock.
Tackmer is a small California company that was first incorporated in 1965. When Tackmer first issued stock, it received two different kinds of consideration. Plaintiffs and another party assigned…
2Cases cited7 opinions
- Gamman v. CommissionerUnited States Tax Court · 1966
- Harold C. & Margaret I. Kean v. Commissioner of Internal Revenue, Inga L. Bardahl v. Commissioner of Internal Revenue, Ole Bardahl v. Commissioner of Internal Revenue, Murdock D. & Mary Ellen MacPherson v. Commissioner of Internal Revenue, William R. & Dorothy L. MacPherson v. Commissioner of Internal Revenue, C. E. Milam & Verda Milam v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
- Parker Oil Co. v. CommissionerUnited States Tax Court · 1972
- Amory Cotton Oil Company, Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1972
- Shores Realty Company, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Broadwater v. DunhamDistrict Court, E.D. New York · 1979