John C. Stanley, III v. United States

Fifth Circuit

John C. Stanley, III v. United States

599 F.2d 672, 44 A.F.T.R.2d (RIA) 5396, 1979 U.S. App. LEXIS 12853

CourtCourt of Appeals for the Fifth Circuit

DecidedJuly 27, 1979

Docket77-2314

StatusPublished

Cited by1 cases

This text of 599 F.2d 672 (John C. Stanley, III v. United States) 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.

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John C. Stanley, III v. United States, 599 F.2d 672, 44 A.F.T.R.2d (RIA) 5396, 1979 U.S. App. LEXIS 12853 (5th Cir. 1979).

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Opinion

PER CURIAM:

In this tax case, the taxpayer appeals the grant of summary judgment for the government. The sole issue on appeal is whether the trial court correctly determined the date on which the taxpayer began to “hold,” within the meaning of 26 U.S.C. § 1223, two convertible debentures. For the reasons expressed by the trial court in Judge Ready’s well-reasoned opinion, Stanley v. United States, 436 F.Supp. 581 (N.D.Miss.1977), we conclude that the taxpayer’s holding period began on August 31, 1971, the day after he actually purchased the debentures, instead of on October 2, 1963, the date the taxpayer entered into an agreement to purchase the debentures at maturity. Accordingly, we affirm the judgment of the district court.

AFFIRMED.

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PER CURIAM:

In this tax case, the taxpayer appeals the grant of summary judgment for the government. The sole issue on appeal is whether the trial court correctly determined the date on which the taxpayer began to “hold,” within the meaning of 26 U.S.C. § 1223, two convertible debentures. For the reasons expressed by the trial court in Judge Ready’s well-reasoned opinion, Stanley v. United States, 436 F.Supp. 581 (N.D.Miss.1977), we conclude that the taxpayer’s holding period began on August 31, 1971, the day after he actually purchased the debentures, instead of on October 2, 1963, the date the taxpayer entered into an agreement to purchase the debentures at maturity. Accordingly, we affirm the judgment of the district court.

AFFIRMED.

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599 F.2d 672, 44 A.F.T.R.2d (RIA) 5396, 1979 U.S. App. LEXIS 12853, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-c-stanley-iii-v-united-states-ca5-1979.

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