Legal Opinion

United States v. D.N. Stafford and Flora C. Stafford

Court of Appeals for the Eleventh Circuit

Decided March 19, 1984No. 82-8738PublishedCited by 11 opinions

1Opinion of the Court

R. LANIER ANDERSON, III, Circuit Judge:

Taxpayers DeNean and Flora Stafford appeal the district court’s summary judgment in favor of the government on their refund action for allegedly overpaid taxes. The refund action involves the Staffords’ 1969 tax return, in which they did not account for their receipt of a limited partnership interest valued at $100,000. The taxpayers argue that the partnership share qualified for nonreeognition treatment under I.R.C. § 721(a) because it was received in “exchange” for “property” they contributed to the partnership. 1 The district court held that…

2Cases cited25 opinions

  1. Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
  2. Lilly v. CommissionerSupreme Court of the United States · 1952
  3. United States v. SanchezSupreme Court of the United States · 1950
  4. Robert P. Shook and Barbara I. Shook v. United StatesCourt of Appeals for the Eleventh Circuit · 1983
  5. Cox Broadcasting Corp. v. National Collegiate Athletic Ass'nSupreme Court of Georgia · 1982

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3Cited by11 opinions

  1. Ninth Ave. Remedial Group v. Allis-Chalmers Corp.District Court, N.D. Indiana · 1996
  2. Colonnade Condominium, Inc. v. CommissionerUnited States Tax Court · 1988
  3. Superior Trading, LLC v. Comm'rUnited States Tax Court · 2011
  4. Principal Life Insurance v. United StatesUnited States Court of Federal Claims · 2006
  5. Campbell v. CommissionerUnited States Tax Court · 1990

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