Opinion · Court of Appeals for the Sixth Circuit

Peggy Hudson Ogilvie, Admx. v. Commissioner of Internal Revenue, Hillsman Taylor v. Commissioner of Internal Revenue

216 F.2d 748

Type
Opinion
Court
Court of Appeals for the Sixth Circuit
Jurisdiction
Federal
Date
1954-10-20
Topic
general

PER CURIAM. This cause was heard upon the record, briefs and argument of counsel for the respective parties; And the Court being of the opinion that the receipt by the petitioners in May 1945 of $21,150 in cash from the judgment debtor Cole “in full settlement” of the $75,702.12 judgment against him, which petitioners had purchased in June 1943 from the judgment creditor for $11,004, was not a “sale or exchange of a capital asset” within the meaning of Section 117(a) (4), Internal Revenue Code, 26 U.S.C.A.; United States v. Bur *749 rows Bros. Co., 6 Cir., 133 F.2d 772; Wenger v. Commissioner, 42 B.T.A. 225, 232, affirmed 6 Cir., 127 F.2d 523, certiorari denied 317 U.S. 646, 63 S.Ct. 40, 87 L.Ed. 520; Hale v.

Citator

UpLaw has not yet analyzed Peggy Hudson Ogilvie, Admx. v. Commissioner of Internal Revenue, Hillsman Taylor v. Commissioner of Internal Revenue. The absence of a flag is not a finding that it is good law.

Cited by
16 opinions