Legal Opinion
David D. Parrish v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided February 23, 1999No. 98-1121PublishedCited by 19 opinions
1Opinion of the CourtLoken, Circuit J.
During tax years 1988, 1989, and 1990, David Parrish received sizeable payments from M & L Business Machine Company (“M & L”) that he did not report on his federal income tax returns. The Commissioner of Internal Revenue assessed substantial tax deficiencies, plus penalties or additions to tax for each of those three years. The Tax Court substantially upheld the deficiencies. Parrish appeals, arguing that the payments from M & L constituted a return of capital or principal, not taxable income, and alternatively that he is entitled to a shareholder’s deduction for the pass-through losses of M…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Burnet v. LoganSupreme Court of the United States · 1931
- Bennett Paper Corporation and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1983
- Underhill v. CommissionerUnited States Tax Court · 1966
9 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Estate of True v. CommissionerCourt of Appeals for the Tenth Circuit · 2004
- Larry L. Sather v. CIRCourt of Appeals for the Eighth Circuit · 2001
- Estate of Alton Bean, Deceased Gary A. Bean, Administrator Mable Bean v. Commissioner of Internal Revenue, Gary A. Bean Cynthia Bean v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2001
- Broz v. Comm'rUnited States Tax Court · 2011
- Gerald E. Toberman and Nancy J. Toberman v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2002
14 more not listed; retrieve them via the Exa API.