JONES ET AL.

v.

ST. MARY'S ROMAN CATHOLIC CHURCH, OPERATING AS ST. MARY'S ROMAN CATHOLIC SCHOOL (GRAMMAR)

Citator

Cited By

• Sochurek v. Commissioner OF Internal Revenue, 300 F.2d 34 (7th Cir. 1962)
  …n goes on to observe that the “same thing may be said of the cases rejecting the claims of technicians to bona fide residence in various remote areas of the world.” Typical of such cases is Jones v. Kyle, 10 Cir., 190 F. 2d 353 (1951), cert. denied, 342 U.S. 886, 72 S.Ct. 175, 96 L.Ed. 664. Our considered judgment is that the factual situations and rationale of the cases sustaining claims of bona fide residence in a foreign country5 are more analogous to the instant case than those principally relied on by…

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• Peter PAN Seafoods, Inc. v. United States, 417 F.2d 670 (9th Cir. 1969)
  …is was the purpose, or a part of the deal, at the time Ajax was founded and purchased the notes. Apparently it could not prove such a plan. See ACF-Brill Motors Co. v. Commissioner of Internal Revenue, 3 Cir., 189 F. 2d 704, 707, cert. denied, 1951, 342 U.S. 886, 72 S.Ct. 176, 96 L.Ed. 665. The district court found that Ajax was formed primarily, but not solely, for the purpose of avoiding federal income tax to New Harris on the purchase of the notes. It relied on this tax avoidance motive plus the close r…
• Commissioner OF Internal Revenue v. Lyon Tyler Matthew, 335 F.2d 231 (5th Cir. 1964)
  …he treaties to make c^ear that while the result here is the same as in Downs v. Commissioner, 9 1948, 166 F. 2d 504, cert. denied, 1948, 334 U.S. 832, 68 S.Ct. 1346, 92 L.Ed. 1759, and Jones v. Kyle, 10 Cir., 1951, 190 F. 2d 353, cert. denied, 1951, 342 U.S. 886, 72 S.Ct. 175, 96 L.Ed. 664, we re^y> ap did such decisions, on limited, restricted nature of the employment in terms of time and nature wor^ ke accomplished, Whether for 20 days or for 20 years, employment under the arrangement authorized by such…