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Harry K. Oliphint and Anna Leblanc Oliphint v. Commissioner of Internal Revenue

Harry K. OLIPHINT and Anna LeBlanc Oliphint, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Oliphint v. Comm'r of Internal Revenue, 234 F.2d 699 (5th Cir. 1956)
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Court
Court of Appeals for the Fifth Circuit · U.S. Courts of Appeals
Decided
June 15, 1956
Docket
No. 15923_1
Judges
Hutcheson, Rives, Brown
Citations
234 F.2d 69949 A.F.T.R. (P-H) 14891956 U.S. App. LEXIS 5076

Opinion — Per Curiam

PER CURIAM.

This petition for review of the decision 1

of the Tax Court, that no non-business bad debt loss resulted from taxpayer’s dealing with their puppet family corporation. It attacks, as without basis in the record, the findings and conclusions of the Tax Court: that taxpayers’ evidence fails to overcome the presumption of correctness attached to the commissioner’s determination, that the eor-poration was a fiction and puppet for tax purposes and that the so-called sale to a member of the family to establish market value was a pretense and a sham.

We cannot agree. We are, on the contrary, of the clear opinion that, for the reasons stated in the opinion of the Tax Court, the decision was right and should be affirmed.

1

. 24 T.C. 744 .

How later courts describe this case

No later court has written an explanatory parenthetical about this case yet.

Cited by 15 cases

View all citing references →
1959: 21963: 11964: 11965: 11966: 21968: 21970: 11972: 11973: 11979: 11985: 11993: 119592026peak 1959 · 2

Relies on it most ⓘ

  1. Osterman v. Commissioner50 T.C. 970 (Tax Ct. 1968)
  2. STIVERS v. COMMISSIONER1973 T.C. Memo. 244
  3. United States v. Ophelia Johnson and Ophelia R. Johnson, as Under the Last Will and Testament of Clifford L. Johnson, Deceased331 F.2d 943 (5th Cir. 1964)
  4. Gittens v. Commissioner49 T.C. 419 (Tax Ct. 1968)
  5. Reinhardt v. Commissioner85 T.C. No. 29
  6. Funkhouser v. Commissioner44 T.C. 178 (Tax Ct. 1965)

Most recent

  1. Vidrine v. Commissioner1993 T.C. Memo. 308
  2. Reinhardt v. Commissioner85 T.C. No. 29
  3. Gegax v. Commissioner73 T.C. 329 (Tax Ct. 1979)
  4. STIVERS v. COMMISSIONER1973 T.C. Memo. 244
  5. Patty R. Smith v. United States460 F.2d 1005 (6th Cir. 1972)
  6. Fidelity Commercial Co. v. Commissioner55 T.C. 483 (Tax Ct. 1970)

Citing references are not a citator: they show that a later opinion cites this case, not whether it followed, distinguished, or overruled it. Check negative history before relying on this case.

Authorities cited 0

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