Legal Opinion

Morrison v. United States

District Court, N.D. Ohio

Decided September 7, 1977No. C74-504PublishedCited by 5 opinions

1Opinion of the Court

MEMORANDUM OPINION ORDER

MANOS, District Judge.

This is an action for the recovery of income taxes alleged to have been erroneously assessed by the United States. Jurisdiction is based on 28 U.S.C. § 1346(a) (1970) and 26 U.S.C. § 7422 (1970).

The plaintiff 1 filed a federal income tax return for the year 1970 in which he reported the proceeds from the sale of certain properties as long-term capital gains. Upon audit and examination of the plaintiff’s 1970 tax return, the Internal Revenue Service (IRS) determined that the proceeds from the sale of these properties should have been reported as…

2Cases cited21 opinions

  1. First Nat. Bank of Ariz. v. Cities Service Co.Supreme Court of the United States · 1968
  2. United States v. Felt & Tarrant Manufacturing Co.Supreme Court of the United States · 1931
  3. McFeely v. CommissionerSupreme Court of the United States · 1935
  4. Merrill v. CommissionerUnited States Tax Court · 1963
  5. McAllister v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946

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3Cited by5 opinions

  1. Waimea Falls Park, Inc. v. BrownHawaii Intermediate Court of Appeals · 1985
  2. Case v. United StatesCourt of Appeals for the Sixth Circuit · 1980
  3. Case v. United StatesCourt of Appeals for the Sixth Circuit · 1980
  4. Mario's Enterprises, Inc. v. Morton-Norwich Products, Inc.District Court, W.D. Kentucky · 1980
  5. In Re CollumUnited States Bankruptcy Court, N.D. Texas · 1991

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