Legal Opinion

Morton E. Cole v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided July 17, 1973No. 837, Docket 73-1253PublishedCited by 8 opinions

1Opinion of the Court

MOORE, Circuit Judge:

This appeal is from decisions of the Tax Court, Leo H. Irwin, Judge, entered October 25, 1972, determining liabilities in taxpayers’ income tax returns for the years 1965 through 1968 in the total amount of $6,184.29. (See 31 T.C.M. 870 (1972)). Taxpayers Cyril Cole and Jean E. Cole, husband and wife, were found liable for a tax deficiency of $4,257.07; taxpayer Morton Cole, brother of Cyril, was found liable for a deficiency of $1927.22. Hereinafter, the term “taxpayers” will refer to Morton and Cyril Cole.

I. The Facts

Taxpayers are brothers who for many years have been…

2Cases cited3 opinions

  1. Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
  2. B. Forman Company, Inc. v. Commissioner of Internal Revenue, McCurdy & Company, Inc. v. Commissioner of Internal Revenue, B. Forman Company, Inc. v. Commissioner of Internal Revenue, McCurdy & Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1972
  3. Cole v. CommissionerUnited States Tax Court · 1972

3Cited by8 opinions

  1. Tulia Feedlot, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1975
  2. Texas Instruments Incorporated, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
  3. Seminole Thriftway, Inc. v. United StatesUnited States Court of Federal Claims · 1998
  4. Allison Corp. v. CommissionerUnited States Tax Court · 1977
  5. Fogg v. CommissionerUnited States Tax Court · 1987

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