Legal Opinion
Herbert and Marsha Stoller v. Commissioner of Internal Revenue
Court of Appeals for the D.C. Circuit
Decided October 6, 1993No. 91-1647, 92-1087, 92-1089, 92-1090 and 92-1091PublishedCited by 16 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge D.H. GINSBURG.
D.H. GINSBURG, Circuit Judge:
Herbert and Marsha Stoller appeal and the Commissioner of Internal Revenue cross- appeals a judgment of the Tax Court determining the Stollers’ income tax liabilities for the years 1979 through 1981 with respect to income from a certain partnership’s investments in securities. Applying the Internal Revenue Code as it read prior to the addition of § 1234A in 1981, we uphold the position of the taxpayers in both appeals.
I. Background
From 1979 to 1982 Herbert Stoller was a partner in Holly Trading Associates,…
2Cases cited8 opinions
- Pension Benefit Guaranty Corporation v. LTV Corp.Supreme Court of the United States · 1990
- United States v. PriceSupreme Court of the United States · 1960
- United States v. TexasSupreme Court of the United States · 1993
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
- Ivan K. Landreth Lucille Landreth v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Keeler v. CommissionerCourt of Appeals for the Tenth Circuit · 2001
- Estate of Israel v. CommissionerUnited States Tax Court · 1997
- Jonathan P. Wolff and Margaret A. Wolff v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
- Estate of Israel v. CommissionerCourt of Appeals for the D.C. Circuit · 1998
- Herbert v. CommissionerCourt of Appeals for the D.C. Circuit · 1993
11 more not listed; retrieve them via the Exa API.