Legal Opinion
Stanley H. Brams v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided May 17, 1984No. 83-1387PublishedCited by 7 opinions
1Per curiam
The petitioner-taxpayer appeals from a decision of the Tax Court denying a capital gain allowance with respect to certain income. The issues presented on this appeal are, (1) whether the Tax Court correctly held that income received by the taxpayer in exchange for certain stock came within the purview of I.R.C. § 304(a)(1) and was therefore taxable by virtue of §§ 301, 302, and 316 as a dividend, 1 and (2) whether the Tax Court was correct in holding that the income received by the taxpayer could not be reported on an installment basis. We conclude that the Tax Court properly resolved both…
2Cases cited8 opinions
- United States v. DavisSupreme Court of the United States · 1970
- Commissioner of Internal Revenue v. Hyman H. Berghash and Rose Berghash, Commissioner of Internal Revenue v. Delavan-Bailey Drug Co., Inc.Court of Appeals for the Second Circuit · 1966
- Berghash v. CommissionerUnited States Tax Court · 1965
- Commissioner of Internal Revenue v. John M. Stickney, of the Estate of Henry McK Haserot, and Bonnie C. HaserotCourt of Appeals for the Sixth Circuit · 1968
- Samuel E. Radnitz, Jr., and Hattie Radnitz v. United StatesCourt of Appeals for the Second Circuit · 1961
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Gunther v. CommissionerUnited States Tax Court · 1989
- Principal Life Insurance v. United StatesUnited States Court of Federal Claims · 2006
- Russell v. CommissionerCourt of Appeals for the Sixth Circuit · 1987
- Russell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
- Estate of Zimmerman v. CommissionerUnited States Tax Court · 1985
2 more not listed; retrieve them via the Exa API.