Legal Opinion
Emory K. Crenshaw, as of the Estate of Frances Wood Wilson, Deceased v. United States
Court of Appeals for the Fifth Circuit
Decided January 14, 1972No. 30798PublishedCited by 45 opinions
1Opinion of the Court
JOHN R. BROWN, Chief Judge:
In this hotly contested suit for refund of Federal income taxes an ingenious taxpayer and a skeptical tax collector vigorously dispute the legal characterization of an imaginative financial maneuver. If the elaborate multi-stage transaction in question amounted to no more than a “sale or exchange” of a partnership interest under § 7411 of the *474Internal Revenue Code of 1954, the Commissioner properly assessed and collected a $47,128.92 deficiency. On the other hand, if it was merely a “liquidating distribution” of a partnership interest governed by § 736(b) 2, the…
2Cases cited23 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. TowerSupreme Court of the United States · 1946
- Higgins v. SmithSupreme Court of the United States · 1940
18 more not listed; retrieve them via the Exa API.
3Cited by45 opinions
- Rauenhorst v. Comm'rUnited States Tax Court · 2002
- Gulfstream Land & Development Corp. v. CommissionerUnited States Tax Court · 1979
- Biggs v. CommissionerUnited States Tax Court · 1978
- TRUE v. United StatesCourt of Appeals for the Tenth Circuit · 1999
- James and Martha Kuper and Charles and Kathleen Kuper, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Fifth Circuit · 1976
40 more not listed; retrieve them via the Exa API.