Legal Opinion
Kappel v. United States
Court of Appeals for the Third Circuit
Decided February 1, 1971No. Nos. 18852, 18853PublishedCited by 20 opinions
1Opinion of the Court
OPINION OF THE COURT
ADAMS, Circuit Judge.
The taxpayers in this case improperly received distributions from four employees’ pension trusts and upon threat of assessment by the Internal Revenue Service (“the Service”) paid an income tax on the distributions. Proceeding to restore the distributions to the respective pension trusts, the taxpayers then deducted on their 1961 return, pursuant to § 1341 of the Internal Revenue Code of 1954 (“the Code”),1 the amount of the income tax paid pursuant to the threatened assessment. The Internal Revenue Service disallowed the dedue*1224tion. The taxpayers paid…
2Cases cited12 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Healy v. CommissionerSupreme Court of the United States · 1953
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
7 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Alcoa, Inc. v. United StatesCourt of Appeals for the Third Circuit · 2007
- American Sterilizer Company, in No. 79-1445 v. Sybron Corporation and Castle Company, a Division of Sybron Corporation, in No. 79-1446Court of Appeals for the Third Circuit · 1980
- Cinergy Corp. v. United StatesUnited States Court of Federal Claims · 2003
- Albert L. Shipley, Jr. And Evelyn Needham, Formerly Shipley v. United StatesCourt of Appeals for the Ninth Circuit · 1979
- Barrett v. CommissionerUnited States Tax Court · 1991
15 more not listed; retrieve them via the Exa API.