Legal Opinion
Commissioner of Internal Revenue v. J. I. Morgan and Frances Morgan
Court of Appeals for the Ninth Circuit
Decided December 11, 1959No. 16395PublishedCited by 45 opinions
1Opinion of the Court
POPE, Circuit Judge.
The facts which concern this review are set forth in the Findings of Fact of the Tax Court as follows:
“On or about August 10, 1937, J. I. Morgan acquired an ‘Accumulative Investment Certificate,’ Series F.-232668, from Investors Syndicate (presently known as Investors Diversified Services, Inc.) of Minneapolis, Minnesota. Under the terms of the certificate, the issuing company agreed to pay to Morgan (with certain options) at the expiration of 15 years, an amount in excess of his aggregate payments. On September 28, 1952, J. I. Morgan exercised one of the available options…
2Cases cited12 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Commissioner v. HansenSupreme Court of the United States · 1959
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
7 more not listed; retrieve them via the Exa API.
3Cited by45 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- United States v. Midland-Ross Corp.Supreme Court of the United States · 1965
- First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
- Stanton v. CommissionerUnited States Tax Court · 1960
- Baker Commodities, Inc. v. CommissionerUnited States Tax Court · 1967
40 more not listed; retrieve them via the Exa API.