Legal Opinion

F. W. Drybrough v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided October 31, 1967No. 17355PublishedCited by 8 opinions

1Per curiam

This case is before the Court on petition of F. W. Drybrough and the Estate of Marion S. Drybrough, Deceased, to review a decision of the Tax Court. Deficiencies in the joint tax returns of F. W. Drybrough and his wife Marion, for the years 1959 and 1960, are involved. On March 2, 1959, F. W. Drybrough, whom we will refer to as the Taxpayer, sold the assets of a proprietorship known as “United Mercantile Agencies” to United Mercantile Agencies, Inc.

The sole question presented on this review is whether certain assets known as Gold Files and Green Files were capital assets so that gain from…

2Cases cited4 opinions

  1. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  2. State Farm Mutual Automobile Insurance v. PalmerSupreme Court of the United States · 1956
  3. Mansfield Journal Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1960
  4. Drybrough v. CommissionerUnited States Tax Court · 1966

3Cited by8 opinions

  1. First Pennsylvania Banking & Trust Co. v. CommissionerUnited States Tax Court · 1971
  2. Hollywood Baseball Association v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
  3. John B. Franzwa, Inc. v. Community Gresham Broadcasting Corp. (In Re Columbia River Broadcasting, Inc.)United States Bankruptcy Court, D. Oregon · 1989
  4. Avers v. CommissionerUnited States Tax Court · 1988
  5. Beltzhoover v. CommissionerUnited States Tax Court · 1991

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