Legal Opinion

Commissioner v. Callner

Court of Appeals for the Seventh Circuit

Decided March 14, 1961No. Nos. 13178-13180PublishedCited by 6 opinions

1Opinion of the Court

KNOCH, Circuit Judge.

The Commissioner of Internal Revenue has petitioned for review of the Tax Court’s decisions that, contrary to the Commissioner’s contention, transfer of property to the taxpayers in 1950 was not a taxable dividend distribution.

The facts are largely stipulated and uncontested. The Commissioner asks this Court to review the legal effect of the facts shown by the record and to sub*643stitute its judgment for that of the Tax Court.

Sarah Callner and Esta Okrent are included as respondents here only because they filed joint income tax returns with their husbands for the taxable…

2Cases cited5 opinions

  1. Helvering v. SalvageSupreme Court of the United States · 1936
  2. Inglis v. FoheyWisconsin Supreme Court · 1908
  3. Mueller v. Novelty Dye WorksWisconsin Supreme Court · 1956
  4. Olsen v. OrtellWisconsin Supreme Court · 1953
  5. Jennings v. United StatesCourt of Appeals for the Seventh Circuit · 1959

3Cited by6 opinions

  1. Nicholls, North, Buse Co. v. CommissionerUnited States Tax Court · 1971
  2. In the Matter of Charles A. Steen, Debtor. Dick Dimond, Trustee v. United StatesCourt of Appeals for the Ninth Circuit · 1975
  3. Ralph L. Brutsche and Ingrid Brutsche v. Commissioner of Internal Revenue, Ruth L. Farley v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1978
  4. Commissioner of Internal Revenue v. Julius Callner, Sarah Callner, Commissioner of Internal Revenue v. Morris J. Okrent, Esta Okrent, Commissioner of Internal Revenue v. Abner E. KopsCourt of Appeals for the Seventh Circuit · 1961
  5. McMinn v. CommissionerUnited States Tax Court · 1962

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