Legal Opinion
Sumner E. And Barbara P. Brown v. The United States
United States Court of Claims
Decided June 14, 1968No. 35-65PublishedCited by 10 opinions
1Opinion of the Court
OPINION
LARAMORE, Judge.
This case involves another aspect of the income tax consequences which have burgeoned from the transactions devised by Livingstone & Company (hereinafter referred to as Livingstone). The record before us is a stipulation of facts which, succinctly stated, discloses a typical “Livingstone” transaction.
Plaintiffs, Sumner E. and Barbara P. Brown, husband and wife, filed joint Federal personal income tax returns for the calendar years ending December 31, 1955 and December 31, 1956.
On November 16, 1954, Sumner E. Brown, hereinafter sometimes referred to as plaintiff,…
2Cases cited29 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- Carl E. Weller and Emily I. Weller v. Commissioner of Internal Revenue, W. Stuart Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Albert Gordon MacRae and Sheila MacRae v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
24 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Fox v. CommissionerUnited States Tax Court · 1984
- Smith v. CommissionerUnited States Tax Court · 1982
- Estate of Martin M. Melcher, Etc. v. Commissioner of Internal Revenue, Estate of Martin M. Melcher, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1973
- Estate of Melcher v. CommissionerUnited States Tax Court · 1970
- Schell v. United StatesUnited States Court of Federal Claims · 2008
5 more not listed; retrieve them via the Exa API.