Estate of Wilson v. Commissioner
This text of 255 F.2d 702 (Estate of Wilson v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
The executors of Sam E. Wilson, Jr., here challenge the correctness of a determination of his Federal income tax liability for 1948 as made by the Tax Court. Its opinion is reported in 27 T.C. 976. We are in accord with the Tax Court’s conclusions. Had the taxpayer adopted a different form for the particular transaction the tax incident might have been different. Cf. Zenz v. Quinlivan, 6 Cir., [703]*7031954, 213 F.2d 914. The difference in the factual situation makes Mayer v. Don-nelly, 5 Cir., 1957, 247 F.2d 322, inapplicable. For the reasons assigned by the Tax Court in its opinion its judgment is
Affirmed.
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255 F.2d 702, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-wilson-v-commissioner-ca5-1958.