Legal Opinion

Milton L. Halle and Rachel N. Halle, His Wife v. United States

Court of Appeals for the Fourth Circuit

Decided May 31, 1965No. 9687PublishedCited by 7 opinions

1Opinion of the Court

BOREMAN, Circuit Judge.

Taxpayers, 1 Milton L. and Rachel N. Halle, appeal from a judgment of the District Court denying them the claimed, right to recover income taxes plus interest alleged to have been improperly assessed and collected. 2

The facts were stipulated in the lower' court. Prior to 1954 Halle had made charitable contributions to Damil Foundation, Incorporated (herein called the; Foundation), an exempt charitable corporation. Interested in continuing the-donations, taxpayer was advised of the-tax benefits flowing from transactions in. which he engaged as hereinafter recited. So…

2Cases cited19 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Knetsch v. United StatesSupreme Court of the United States · 1960
  3. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  4. Joseph H. Bridges and Lillier J. Bridges v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
  5. Commissioner v. KorellSupreme Court of the United States · 1950

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3Cited by7 opinions

  1. Karme v. CommissionerUnited States Tax Court · 1980
  2. Fidelity International Currency Advisor a Fund, LLC v. United StatesDistrict Court, D. Massachusetts · 2010
  3. Rothschild v. United StatesUnited States Court of Claims · 1969
  4. Rothschild v. United StatesUnited States Court of Claims · 1969
  5. N. Louis Stone v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1966

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