Legal Opinion
Nielsen v. United States
Court of Appeals for the Sixth Circuit
Decided June 29, 1964No. Nos. 15399, 15400PublishedCited by 13 opinions
1Opinion of the Court
EDWARDS, Circuit Judge.
This appeal involves two large stock transactions wherein a Nashville stockbroker partnership, J. C. Bradford & Company, acted as intermediary between seller and ultimate purchaser. In each Bradford had title to the stock more than six months, assigned the stock to its house “investment account,” took a “profit” on the resales rather than a “commission,” and the Bradford partners claimed the “profits” as capital gains in their income tax returns.
The Internal Revenue Department disallowed these sums as capital gains and reassessed them as ordinary income. This suit was…
2Cases cited6 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Mrs. Guilberta Dakin Maggiore v. J. C. BradfordCourt of Appeals for the Sixth Circuit · 1962
- W. Raymond Denney v. Phillips & Buttorff CorporationCourt of Appeals for the Sixth Circuit · 1964
1 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Commissioner of Internal Revenue v. Charles N. Anderson and Grace M. AndersonCourt of Appeals for the Sixth Circuit · 1966
- Browne v. United StatesUnited States Court of Claims · 1966
- Currie v. CommissionerUnited States Tax Court · 1969
- Stoller v. CommissionerUnited States Tax Court · 1983
- Browne v. United StatesUnited States Court of Claims · 1966
8 more not listed; retrieve them via the Exa API.