Legal Opinion

Andrew M. Spheeris and Ismene A. Spheeris v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided January 25, 1961No. 13093_1PublishedCited by 27 opinions

1Opinion of the Court

HASTINGS, Chief Judge.

This petition to review a decision of the Tax Court of the United States raises one central issue — the legal characterization for income tax purposes of certain payments made by Milwaukee Towne Corporation (Towne) to taxpayer Andrew M. Spheeris. Spheeris and his wife Ismene, joint taxpayers and petitioners, here contend that such payments were loans by the corporation to them and as such were not reportable income. The Commissioner argues that the payments were dividends and therefore constituted taxable income. The Tax Court held that the payments in question were…

2Cases cited7 opinions

  1. Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
  2. Milwaukee Towne Corp. v. Loew's, Inc.Court of Appeals for the Seventh Circuit · 1951
  3. Ruth T. Lengsfield, Coralie Mayer Lengsfield and Blanche L. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
  4. Regensburg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
  5. Carl G. Ortmayer and Hilda B. Ortmayer, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1959

2 more not listed; retrieve them via the Exa API.

3Cited by27 opinions

  1. United States v. Morris C. Goldberg, Also Known as Moe Goldberg and M. C. GoldbergCourt of Appeals for the Third Circuit · 1964
  2. Alterman Foods, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1975
  3. Ramo, Inc. v. EnglishTexas Supreme Court · 1973
  4. Commissioner v. MakranskyCourt of Appeals for the Third Circuit · 1963
  5. Richard E. Busch Jr. & Jean N. Busch v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984

22 more not listed; retrieve them via the Exa API.

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