Legal Opinion
William E. And Thelma S. Dobson v. The United States
United States Court of Claims
Decided April 17, 1964No. 401-62PublishedCited by 12 opinions
1Opinion of the Court
DURFEE, Judge.
This is a suit for recovery of $11,-054.95 paid as income taxes for the year 1949. The question presented is whether the mitigation statutes, sections 1311 to 1315 of the Internal Revenue Code of 1954, permitted the assessment of deficiencies in 1961 for 1949 income against the taxpayers. They had reported as capital gain in 1948 the entire gain from sale of stock, though part of the sale price was not received until 1949. The Commissioner of Internal Revenue originally asserted a deficiency on the ground that the entire capital gain from the sale of stock should be treated as…
2Cases cited4 opinions
- Cory v. CommissionerUnited States Tax Court · 1955
- Daniel M. Cory and Margot Cory, His Wife v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Cory v. CommissionerUnited States Tax Court · 1958
- Estate of SoRelle v. CommissionerUnited States Tax Court · 1958
3Cited by12 opinions
- A. H. Karpe v. The United States. The United States (Cross-Complainant) v. Birda M. Viera (Cross-Defendant)United States Court of Claims · 1964
- Herbert Birchenough and Edith Birchenough v. The United States. John J. Hurtz and Julia R. Hurtz v. The United StatesUnited States Court of Claims · 1969
- Kent Homes, Inc. v. CommissionerUnited States Tax Court · 1971
- Kent Homes, Inc. v. Commissioner of Internal Revenue, Alton K. Blosser v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1972
- G-B, Inc. v. United StatesDistrict Court, D. Colorado · 1969
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