Legal Opinion

Loren T. Raymond and Corrine Raymond v. United States

Court of Appeals for the Sixth Circuit

Decided August 4, 1959No. 13621PublishedCited by 11 opinions

1Opinion of the Court

SHELBOURNE, District Judge.

The question involved upon this appeal is whether the appellants, husband and wife, the sole stockholders in a corporation which was liquidated in 1952, may revoke their election to be taxed under the provisions of Section 112(b) (7) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 112(b) (7).

The District Court, we think correctly, decided that such election could not be revoked and dismissed the complaint. The judge held that the mistake involved was one of law on the part of complainants’ counsel and tax accountant.

Appellants claim on this appeal that the…

2Cases cited4 opinions

  1. J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
  2. Meyer's Estate v. Commissioner of Internal Revenue. (Three Cases)Court of Appeals for the Fifth Circuit · 1952
  3. Leon Rosenfield, as Administrator, D.B.N.C.T.A. Of Estate of George D. Beaston, Deceased v. United StatesCourt of Appeals for the Third Circuit · 1958
  4. Taylor v. CommissionerUnited States Tax Court · 1960

3Cited by11 opinions

  1. Estate of Stamos v. CommissionerUnited States Tax Court · 1970
  2. National Lead Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
  3. Frank T. Shull and Ann R. Shull v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
  4. Estate of Darby v. WisemanCourt of Appeals for the Tenth Circuit · 1963
  5. Cohen v. CommissionerUnited States Tax Court · 1975

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