Legal Opinion
Estate of Gerald L. Wallace, Deceased, Celia A. Wallace, and Celia A. Wallace v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided July 13, 1992No. 91-7318PublishedCited by 81 opinions
1Opinion of the Court
KRAVITCH, Circuit Judge:
Plaintiffs-Appellants Gerald L. Wallace (“Wallace”), deceased, and Celia A. Wallace, his wife and executrix, appeal from a tax court decision upholding the IRS’s finding of tax deficiencies against the Wallaces for the years 1980 and 1983. The tax court ruled that the Wallaces were not entitled to deduct the entire cost of feed for their cattle-feeding business in the year in which the feed was purchased, and could only deduct the cost in the year the feed was actually consumed because, under 26 U.S.C. § 464, Wallace was a limited entrepreneur who did not “actively…
2Cases cited10 opinions
- Blum v. StensonSupreme Court of the United States · 1984
- Pullman-Standard v. SwintSupreme Court of the United States · 1982
- Cabalceta v. Standard Fruit Co.Court of Appeals for the Eleventh Circuit · 1989
- Neal Demby v. Richard S. Schweiker, in His Capacity as Secretary of the Department of Healthand Human Resources, American Academy of Family PhysiciansCourt of Appeals for the D.C. Circuit · 1981
- Estate of Wallace v. CommissionerUnited States Tax Court · 1990
5 more not listed; retrieve them via the Exa API.
3Cited by81 opinions
- Nelson M. Blohm and Joann M. Blohm v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
- Allen v. Comm'rUnited States Tax Court · 2002
- Maniolos v. United StatesDistrict Court, S.D. New York · 2010
- James L. Redlark Cheryl L. Redlark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
- David Miller Valeria Miller v. United StatesCourt of Appeals for the Eighth Circuit · 1995
76 more not listed; retrieve them via the Exa API.