Legal Opinion
Samueli v. Commissioner
Court of Appeals for the Ninth Circuit
Decided September 15, 2011No. 09-72457, 09-72458PublishedCited by 2 opinions
1Opinion of the Court
Opinion by Judge TASHIMA; Concurrence by Judge RAWLINSON.
ORDER
Petitioners-appellants’ petition for panel rehearing, which is unopposed by respondent-appellee, at least in part, is granted. The Opinion, filed September 15, 2011, slip op. 17597, [658 F.3d 992], is amended, as follows:
1. In the second full paragraph on slip op. at 17619 [658 F.3d at 1003], line 3, the word <purpose> shall be substituted for the word < purchase > in the phrase <a non-tax business or corporate purpose. >
2. The first paragraph on slip op. at 17628 [658 F.3d at 1008], commencing with “This error, however, did not…
2Cases cited16 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- MacKey v. Lanier Collection Agency & Service, Inc.Supreme Court of the United States · 1988
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
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3Cited by2 opinions
- Samueli v. CIRCourt of Appeals for the Ninth Circuit · 2011
- Jason B. Sage v. CommissionerUnited States Tax Court · 2020