Legal Opinion

F. W. Drybrough v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided March 30, 1967No. 16525_1PublishedCited by 12 opinions

1Opinion of the Court

O’SULLIVAN, Circuit Judge.

This matter is before us on the petition of taxpayers, F. W. Drybrough and the executor of the estate of his deceased wife, Citizens Fidelity Bank & Trust Company, to review a decision of the Tax Court of the United States, reported as Drybrough v. Commissioner, 42 T.C. 1029 (1964). Conduct by F. W. Dry-brough is primarily involved and we shall refer only to him as the taxpayer or petitioner. The issues before us are (1) the tax effect of the assumption of liabilities in connection with transfers by Dry-brough to controlled corporations, and (2) the deductibility of…

2Cases cited12 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Quock Ting v. United StatesSupreme Court of the United States · 1891
  3. United States v. HendlerSupreme Court of the United States · 1938
  4. C. Louis Wood and Hallie D. Wood v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
  5. R. A. Bryan and Ruby M. Bryan, C. B. McNairy and Rowena A. McNairy W. H. Weaver and Edith H. Weaver v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960

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

3Cited by12 opinions

  1. Johnson v. CommissionerUnited States Tax Court · 1973
  2. The Wisconsin Cheeseman, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1968
  3. John E. Leslie and Evelyn G. Leslie v. Commissioner of the Internal RevenueCourt of Appeals for the Second Circuit · 1969
  4. John R. Carkhuff Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
  5. H Enters. Int'l v. CommissionerUnited States Tax Court · 1995

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

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