SCHINDELAR

v.

MICHAUD ET AL.

Citator

Cited By

• Commissioner of Internal Revenue v. First Sec. Bank of Utah, 405 U.S. 394 (U.S. 1972)
  …rsed the decision of the Tax Court, 436 F. 2d 1192 (1971), and we granted the Commissioner’s petition for certiorari to resolve a conflict between the decision below and that in Local Finance Corp. v. Commissioner, 407 F. 2d 629 (CA7), cert. denied, 396 U. S. 956 (1969). We now affirm the decision of the Court of Appeals. [*396] Respondents, First Security Bank of Utah, N. A., and First Security Bank of Idaho, N. A. (the Banks), are national banks that, during the tax years, were wholly owned subsidiaries of…

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• B. Forman Co., Inc. v. Commissioner OF Internal Revenue, 453 F.2d 1144 (2d Cir. 1972)
  …al scrutiny to ascertain whether the common control is being used to reduce, avoid, or escape taxes.” Treas.Reg. 1.482-1 (c). To same effect, see Local Finance Corp. v. Commissioner of Internal Revenue, 407 F. 2d 629, 632 (7th Cir.), cert, denied, 396 U.S. 956, 90 S.Ct. 428, 24 L.Ed.2d 420 (1969). To justify the allocation as income to McCurdy and Forman of interest on their loans, it must be found that their waiver of interest “is other than it would have been had the taxpayer in the conduct of his aff…
• United States v. Zamora-Corona, 465 F.2d 427 (9th Cir. 1972)
  …F. 2d 899, 902-903 (2nd Cir. 1960); Contra, McElheny v. United States, 146 F. 2d 932, 933 (9th Cir. 1944). However, the judgments are not necessarily inconsistent. See generally United States v. Davis, 411 F. 2d 927, 930 (7th Cir.), cert. denied, 396 U.S. 956, 90 S.Ct. 429, 24 L.Ed.2d 422 (1969); United States v. Wilson, 342 F. 2d 43, 45 (2nd Cir. 1965). This court has held that when one drives a car laden with contraband, there is a substantial basis from which the trier of fact may infer that the drive…