Legal Opinion
Commissioner of Internal Revenue v. Thompson I. Welch, Individually, Thomspon I. Welch, Individually v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided June 1, 1965No. 20819PublishedCited by 20 opinions
1Opinion of the Court
JOHN R. BROWN, Circuit Judge.
This case is not so much the problem of who did what to whom. Rather, it is who really did the act and when. This simplification is beguiling, however, for specifically inyolved is the right of the Commissioner to make pre-1954 adjustments occasioned by 1957-1958 changes in the Taxpayer’s method of accounting pursuant to § 481, 1 a statutory structure with a laudable aim but with inescapably built-in difficulties. 2 Cf. Graff Chevrolet Co. v. Campbell, 5 Cir., 1965, 343 F.2d 568 [No. 21178, March 29, 1965].
The Tax Court held that the change was initiated by the…
2Cases cited17 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- United States v. PriceSupreme Court of the United States · 1960
- Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
- Sanders v. LeechCourt of Appeals for the Fifth Circuit · 1946
12 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- George C. McGee v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1975
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Charlson Realty Company v. The United StatesUnited States Court of Claims · 1967
- Carolyn Brafman v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1975
15 more not listed; retrieve them via the Exa API.