Legal Opinion
Charles W. Balthrope and Mary v. Balthrope v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided March 3, 1966No. 21916_1PublishedCited by 82 opinions
1Opinion of the Court
WISDOM, Circuit Judge:
Charles W. Balthrope sold his San Antonio radio station for $442,000. A provision in the original contract, later the subject of a separate agreement, allocated $150,000 of the purchase price to payments for the consulting services of Bal-thrope and his wife and for their covenant not to compete. When the Bal-thropes agreed to this allocation, apparently they were unaware of the unfavorable tax consequences. Now better advised, they contend that the agreement allocating $150,000 to consulting and non-competition covenants was a sham because the payments were in fact part…
2Cases cited14 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Michaels v. CommissionerUnited States Tax Court · 1949
- Commissioner of Internal Revenue v. Maurice L. KillianCourt of Appeals for the Fifth Circuit · 1963
- Emmette L. Barran and Martha Barran v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
9 more not listed; retrieve them via the Exa API.
3Cited by82 opinions
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
- Bernard D. Spector v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
- Winn-Dixie Montgomery, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Major v. CommissionerUnited States Tax Court · 1981
77 more not listed; retrieve them via the Exa API.