Legal Opinion
Union Planters National Bank of Memphis v. United States
Court of Appeals for the Sixth Circuit
Decided May 4, 1970No. 19409_1PublishedCited by 63 opinions
1Opinion of the Court
McCREE, Circuit Judge.
This appeal presents the question whether coupon interest collected by a bank as owner of municipal bonds subject to repurchase agreements is exempt from taxation under § 103(a) of the Internal Revenue Code. We hold that under the circumstances of this case it is not, and accordingly we reverse the decision of the District Court, 295 F.Supp. 1151 (W.D.Tenn.1968). Since 1938 or 1939, appellant Bank has purchased municipal bonds 1 from local bond dealers, subject to agreements permitting the Bank to require repurchase .by the dealer at any time at the price paid by the…
2Cases cited8 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Burnet v. HarmelSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
3 more not listed; retrieve them via the Exa API.
3Cited by63 opinions
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- National Labor Relations Board v. Allied Products Corporation, Richard Brothers DivisionCourt of Appeals for the Sixth Circuit · 1977
- United States v. Ingredient Technology Corporation, Formerly Known as Sucrest Corporation, and Robert M. RapaportCourt of Appeals for the Second Circuit · 1983
- E. Keith Owens v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
- Waterman Steamship Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
58 more not listed; retrieve them via the Exa API.