Legal Opinion
William L. Raley and Thelma C. Raley v. United States
Court of Appeals for the Fifth Circuit
Decided March 15, 1974No. 73-1674PublishedCited by 5 opinions
1Opinion of the Court
JOHN R. BROWN, Chief Judge:
The Government in this tax refund suit appeals a decision by the District Court holding that money received by taxpayers 1 in the redemption of four revolving fund retain certificates from agricultural cooperatives was taxable as capital gain rather than as ordinary income. 2 Taxpayers had reported these as capital gains but the Commissioner reclassified the amounts as ordinary income. We conclude that the Judge was both right and wrong and in a sort of Solomonic way, The Noah’s Ark v. Bentley & Felton Corp., 5 Cir., 1961, 292 F.2d 437, 438, 1961 A.M.C. 1641, 1642,…
2Cases cited8 opinions
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Long Poultry Farms, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
- The Oil Screw Noah's Ark and Charles E. Graham v. Bentley & Felton Corporation, Owner of the Oil Screw CudjoeCourt of Appeals for the Fifth Circuit · 1961
- Commissioner of Internal Revenue v. B. A. CarpenterCourt of Appeals for the Fifth Circuit · 1955
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3Cited by5 opinions
- Agway, Inc. v. United StatesUnited States Court of Claims · 1975
- Coastal Chemical Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1977
- Richard B. Osborn Appellant v. R. James NicholsonUnited States Court of Appeals for Veterans Claims · 2007
- Richard B. Osborn Appellant v. R. James NicholsonUnited States Court of Appeals for Veterans Claims · 2007
- The United States v. Agway, Inc., Successor to Cooperative Grange League Federation Exchange, Inc.Court of Appeals for the Federal Circuit · 1982