Legal Opinion
Zychinski v. Commissioner
Court of Appeals for the Eighth Circuit
Decided November 25, 1974No. Nos. 74-1180 and 74-1181PublishedCited by 8 opinions
1Opinion of the Court
TALBOT SMITH, Senior District Judge.
These appeals are taken from judgments of the United States Tax Court assessing tax deficiencies against the taxpayers of some $1,300 in No. 74-1180 and some $125,000 in No. 74-1181. The facts are not in dispute and are set out in more detail in the opinion of the tax court.1 The issue presented involves the interpretation of Int.Rev.Code of 1954, § 1372(e)(5), relating to the termination of a corporation’s “subchapter S” status.2 In 1966 and 1967 Henry J. Richter & Company, Inc. (hereinafter the Company) reported net operating losses which it attempted to…
2Cases cited8 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Western Union Telegraph Co. v. LenrootSupreme Court of the United States · 1945
- Jasper L. House, Jr., and Edra F. House v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1972
- Buhler Mortg. Co. v. CommissionerUnited States Tax Court · 1969
- Marshall v. CommissionerUnited States Tax Court · 1973
3 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Arlie Glen Skelton, Jr. v. General Motors CorporationCourt of Appeals for the Seventh Circuit · 1981
- E. H. Winn, Jr. And Betty Lee Jones Winn v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979
- Davenport v. CommissionerUnited States Tax Court · 1978
- Bradshaw v. United StatesUnited States Court of Claims · 1982
- Kenneth W. Doehring v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1975
3 more not listed; retrieve them via the Exa API.