WILLIAM F. SUTTON AND HELEN C. SUTTON, PETITIONERS-APPELLANTS,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE; JOSEPH W. FLEECE, JR., AND JOANNE M. FLEECE, PETITIONERS-APPELLANTS, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE; JOHN C. PRUITT AND FRANCES M. PRUITT, PETITIONERS-APPELLANTS, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE; JULES DRESSLER AND MURIEL DRESSLER, PETITIONERS-APPELLANTS, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE; R. HUSTON BABCOCK AND SUZANNE BABCOCK, PETITIONERS-APPELLANTS, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE
WILLIAM F. SUTTON AND HELEN C. SUTTON, PETITIONERS-APPELLANTS,
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE; JOSEPH W. FLEECE, JR., AND JOANNE M. FLEECE, PETITIONERS-APPELLANTS, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE; JOHN C. PRUITT AND FRANCES M. PRUITT, PETITIONERS-APPELLANTS, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE; JULES DRESSLER AND MURIEL DRESSLER, PETITIONERS-APPELLANTS, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE; R. HUSTON BABCOCK AND SUZANNE BABCOCK, PETITIONERS-APPELLANTS, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE
788 F.2d 695
Court of Appeals for the Eleventh Circuit (1986)
Positive Treatment
Cited by 4 cases
Opinion of the Court
PER CURIAM:
The judgment of the tax court in these cases is AFFIRMED on the basis of the opinion of the tax court, 84 T.C. 210 (1985).
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Citator
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Hempel v. United States, 14 F.3d 572 (11th Cir. 1994)…therwise imposed by ... section 6213. After trial in the Sutton matter, the tax court ruled in favor of the government. Sutton v. Commissioner, 84 T.C. 210, 226, 1985 WL 15310 (1985). This court affirmed on April 16,1986. Sutton v. Commissioner, 788 F. 2d 695, 696 (11th Cir.1986). For purposes of the instant case, the Sutton decision became final on that date. No further action occurred in this case for nearly two years. Then, on February 17, 1988, the IRS received from the taxpayers a signed Form 872…1 / 2
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Knowlton v. Commissioner OF Internal Revenue, 791 F.2d 1506 (11th Cir. 1986)…General Motors stock. The judgment of the Tax Court is AFFIRMED. No. 85-3694 The decision in this case is controlled by our previous decision in Sutton, et al. v. Commissioner of Internal Revenue, decided by the Eleventh Circuit, April 16, 1986, 788 F. 2d 695. The judgment of the Tax Court is AFFIRMED on the basis of the opinion of the Tax Court, 84 T.C. 210 (1985). . Section 333(e) provides as follows for noncor-porate shareholders receiving a liquidating distribution under‘Section 333: (1) there shal…