GLEN R. HARRIS ET UX., ET AL., PETITIONERS-APPELLANTS,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE
GLEN R. HARRIS ET UX., ET AL., PETITIONERS-APPELLANTS,
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE
439 F.2d 704
United States Court of Appeals for the Ninth Circuit (1971)
Positive Treatment
Cited by 6 cases
Opinion of the Court
PER CURIAM:
The decision is affirmed on the basis of the opinion of the Tax Court judge appearing as Tax Court Memo. 1968-86, filed May 14, 1968, unofficially reported at 27 T.C.M. 405.
Here the Commissioner and the Tax Court collapsed the form of transactions into what they considered the substance. This they cannot do arbitrarily, but on the record, we cannot say it was clearly wrong to do so. Cf. Oesterreich v. Commissioner of Internal Revenue, 9 Cir., 226 F. 2d 798; Robinson v. Elliot, 9 Cir., 262 F. 2d 383; and Estate of Starr v. Commissioner of Internal Revenue, 9 Cir., 274 F. 2d 294.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Fireman's Fund Ins. Co. v. Aalco Wrecking Co., Inc., 466 F.2d 179 (8th Cir. 1972)
-
Nodak OIL Co. v. Mobil OIL Corp., 533 F.2d 401 (8th Cir. 1976)
Authorities Cited
- Walburga Oesterreich v. Commissioner OF Internal Revenue, 226 F.2d 798 (9th Cir. 1955)
- Est. of Delano T. Starr v. Commissioner OF Internal Revenue, 274 F.2d 294 (9th Cir. 1959)
- Robinson v. Elliot, 262 F.2d 383 (9th Cir. 1958)