Legal Opinion

Wilson v. United States

Court of Appeals for the Eighth Circuit

Decided February 11, 1976No. Nos. 74-1937, 74-1938PublishedCited by 28 opinions

1Opinion of the Court

WEBSTER, Circuit Judge.

Following a deficiency determination by the Commissioner of Internal Revenue resulting from the exercise of his reallocation of income powers, taxpayers brought a tax refund suit in the District Court. The government appeals from an adverse judgment.

Before giving a more detailed recitation of the facts in evidence which otherwise may seem complex and confusing, it may be helpful to present in capsule form the genesis of the dispute and the government’s contentions on appeal.

In 1964, taxpayers formed a corporation to provide consulting services in connection with the…

2Cases cited25 opinions

  1. Lucas v. EarlSupreme Court of the United States · 1930
  2. Helvering v. HorstSupreme Court of the United States · 1940
  3. McAllister v. United StatesSupreme Court of the United States · 1954
  4. United States v. BasyeSupreme Court of the United States · 1973
  5. United States v. CarmackSupreme Court of the United States · 1947

20 more not listed; retrieve them via the Exa API.

3Cited by28 opinions

  1. Fireman's Fund Insurance Co., in No. 75-2405 v. Videfreeze Corporation, and David E. Chinnery Development Corp., Inno. 75-2406Court of Appeals for the Third Circuit · 1976
  2. Foster v. Comm'rUnited States Tax Court · 1983
  3. Haag v. CommissionerUnited States Tax Court · 1987
  4. Keller v. CommissionerUnited States Tax Court · 1981
  5. United California Bank v. THC Financial Corp.Court of Appeals for the Ninth Circuit · 1977

23 more not listed; retrieve them via the Exa API.

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