Legal Opinion
Gulf Inland Corporation v. United States
Court of Appeals for the Fifth Circuit
Decided April 7, 1978No. 75-3767PublishedCited by 9 opinions
1Opinion of the Court
RONEY, Circuit Judge:
Internal Revenue Code § 541 imposes a penalty tax on the undistributed income of personal holding companies. To avoid that levy, Gulf Inland distributed appreciated property to its shareholders. Under Treas. Reg. § 1.562-1(a) (1958), Gulf Inland could only take a deduction from income for the adjusted basis of the property, even though the shareholders who received it would have to pay individual taxes on the higher fair market value. Because a then-recent case from the Sixth Circuit, H. Wetter Manufacturing Co. v. United States, 458 F.2d 1033 (6th Cir. 1972), had held…
2Cases cited14 opinions
- Chevron Oil Co. v. HusonSupreme Court of the United States · 1971
- Dixon v. United StatesSupreme Court of the United States · 1965
- Fulman v. United StatesSupreme Court of the United States · 1978
- United States v. Estate of DonnellySupreme Court of the United States · 1970
- Lawrence v. CommissionerUnited States Tax Court · 1957
9 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
- Robert Fehlhaber v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1992
- H. Douglas Wilson, and Roberta D. Wilson v. United StatesCourt of Appeals for the Sixth Circuit · 1978
- Maher v. Zapata Corp.District Court, S.D. Texas · 1980
- C. Blake McDowell, Inc. v. CommissionerUnited States Tax Court · 1978
4 more not listed; retrieve them via the Exa API.