Legal Opinion
Los Angeles Extension Company v. United States of America, Security First National Bank v. United States
Court of Appeals for the First Circuit
Decided March 19, 1963No. 17991, 17992PublishedCited by 20 opinions
1Opinion of the Court
JERTBERG, Circuit Judge.
The basic issue presented on these appeals is whether gains realized by appellant, Los Angeles Extension Company, hereafter taxpayer, from sales in 1953 of four parcels of real property are tax able as ordinary income or as long-term capital gains.
In its federal income tax return for 1953, taxpayer reported such gains as having been realized from the sale of capital assets taxable as long-term capital gains, and paid the tax shown on such returns. Upon audit, the Internal Revenue Service determined that the four parcels of real property were not capital assets and that…
2Cases cited10 opinions
- Rollingwood Corp. v. Commissioner of Internal Revenue. Bohannon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1951
- Stockton Harbor Industrial Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
- Reginald G. Hearn and Mary L. Hearn, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Pool v. CommissionerCourt of Appeals for the Ninth Circuit · 1957
- Robert E. Austin and Marian H. Austin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
5 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Rockwell v. CommissionerUnited States Tax Court · 1972
- McManus v. CommissionerCourt of Appeals for the Ninth Circuit · 1978
- Redwood Empire Savings & Loan Association v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Parkside, Inc. And Beaconcrest, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1977
15 more not listed; retrieve them via the Exa API.