Cases by Issue - Federal Taxation of Gifts

United States v. Galletti

Mon, 05 Jan 2009 17:44:54 +0000

Case Basics

Docket No.

02-1389

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Abel C. Galletti, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 114 (2004)

Granted

Monday, June 23, 2003

Argued

Monday, January 12, 2004

Decided

Tuesday, March 23, 2004

Advocates

David R. Haberbush (argued the cause for Respondents)

Kent L. Jones (argued the cause for Petitioner)

Facts of the Case

Abel Galletti and his wife, along with another couple, the Briguglios, formed a business partnership. The partnership underpaid its federal employment taxes, and the IRS assessed the unpaid taxes against the partnership (meaning the partnership would be forced to pay the taxes). According to the Internal Revenue Code, if a tax debt is assessed within three years after the return was filed, the government has 10 additional years to collected the money.

More than three years later, the Gallettis and the Briguglios separately filed for bankruptcy. The IRS made a claim in bankruptcy court against the two couples for the taxes assessed against the partnership. The couples objected, arguing that because the partners themselves had not been separately assessed, the statute of limitations had not been extended to the partners.

The bankruptcy court ruled against the IRS, holding that the IRS must assess tax claims against individual partners, not just the partnership, in order to later collect on those claims from the individuals. The district court and a Ninth Circuit Court of Appeals panel both affirmed the decision.

Question

To qualify for the 10-year extension in the statute of limitations, does the government need to assess - beyond just the partnership that owes money - each individual partner for the debt?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Internal Revenue Code

No. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that the IRS' assessment against the partnership was sufficient to extend the statute of limitations by 10 years to collect the money from the partners themselves. The Internal Revenue Code does not require the government to make separate assessments of a single debt against people or entities secondarily liable in order to extend the statute of limitations. The statute of limitations extension is attached to the debt - without reference to the entities who owe the debt.

Commissioner v. Estate of Hubert

Mon, 05 Jan 2009 16:15:53 +0000

Case Basics

Docket No.

95-1402

Petitioner

Commissioner

Petitioner Type

Petitioner

Respondent

Estate of Hubert

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

520 U.S. 93 (1997)

Argued

Tuesday, November 12, 1996

Decided

Tuesday, March 18, 1997

Advocates

Kent L. Jones (Department of Justice, argued the cause for the petitioner)

David D. Aughtry (Argued the cause for the respondent)

Facts of the Case

The executors of Otis C. Hubert's substantial estate filed a federal estate tax return about a year after his death. Subsequently, the Commissioner of Internal Revenue issued a notice of deficiency, claiming underreporting of federal estate tax liability caused by the estate's asserted entitlement to marital and charitable deductions. While the estate's redetermination petition was pending in the Tax Court, the interested parties settled on the use of the estate's assets. The agreement divided the estate's principal, assumed to be worth $26 million, equally between marital trusts and a charitable trust. It also provided that the estate would pay its administration expenses either from the principal or the income of the assets. The estate paid about $500,000 of its nearly $2 million of administration expenses from principal and the rest from income. It then recalculated its tax liability, reducing the marital and charitable deductions by the amount of principal, but not the amount of income, used to pay the expenses. The Commissioner concluded that using income for expenses required a dollar for dollar reduction of the deductions. The Tax Court disagreed, finding that no reduction was required by reason of the executors' power, or the exercise of their power, to pay administration expenses from income. The Court of Appeals affirmed.

Question

Does the cost of administering an estate necessarily reduce the allowed estate-tax deduction for assets left to a spouse or charity?

Conclusion

Decision: 7 votes for Estate of Hubert, 2 vote(s) against
Legal provision: Internal Revenue Code

No. In an opinion authored by Justice Anthony M. Kennedy, the Court ruled that a taxpayer does not have to reduce the estate tax deduction for marital or charitable bequests by the amount of the administration expenses that were paid from income generated during administration by assets allocated to those bequests. "When income is used . . . to pay administration expenses, this does not require the estate tax deductions be diminished," wrote Justice Kennedy.

United States v. Irvine

Mon, 05 Jan 2009 16:23:54 +0000

Case Basics

Docket No.

92-1546

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Irvine et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1993-1994)

Decided By

Rehnquist Court (1993-1994)

Opinion

511 U.S. 224 (1994)

Argued

Monday, December 6, 1993

Decided

Wednesday, April 20, 1994

Advocates

Phillip H. Martin (on behalf of the Respondents)

Kent L. Jones (on behalf of the Plaintiff)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for United States, 0 vote(s) against
Legal provision: Internal Revenue Code

None

Commissioner Of Internal Revenue v. Soliman

Mon, 05 Jan 2009 16:01:14 +0000

Case Basics

Docket No.

91-998

Petitioner

Commissioner Of Internal Revenue

Petitioner Type

Petitioner

Respondent

Soliman

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

506 U.S. 168 (1993)

Argued

Monday, October 5, 1992

Decided

Tuesday, January 12, 1993

Advocates

David M. Sokolow (on behalf of the Respondent)

Kent L. Jones (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Commissioner Of Internal Revenue, 1 vote(s) against
Legal provision: Internal Revenue Code

None

Indopco, Inc. v. Commissioner Of Internal Revenue

Mon, 05 Jan 2009 16:24:02 +0000

Case Basics

Docket No.

90-1278

Petitioner

Indopco, Inc.

Petitioner Type

Petitioner

Respondent

Commissioner Of Internal Revenue

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

503 U.S. 79 (1992)

Argued

Tuesday, November 12, 1991

Decided

Wednesday, February 26, 1992

Advocates

Richard J. Hiegel (on behalf of the Petitioner)

Kent L. Jones ()

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Commissioner Of Internal Revenue, 0 vote(s) against
Legal provision: Internal Revenue Code

None

Davis v. United States

Mon, 05 Jan 2009 17:30:16 +0000

Case Basics

Docket No.

89-98

Petitioner

Davis

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1988-1990)

Decided By

Rehnquist Court (1988-1990)

Opinion

495 U.S. 472 (1990)

Argued

Monday, March 26, 1990

Decided

Monday, May 21, 1990

Advocates

Shirley D. Peterson (on behalf of the Respondent)

Rex E. Lee (on behalf of the Petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Internal Revenue Code

None

Hernandez v. Commissioner

Mon, 05 Jan 2009 17:26:09 +0000

Case Basics

Docket No.

87-963

Petitioner

Hernandez

Petitioner Type

Petitioner

Respondent

Commissioner

Respondent Type

Respondent

Consolidation

No. 87-1616

Heard By

Rehnquist Court (1988-1990)

Decided By

Rehnquist Court (1988-1990)

Opinion

490 U.S. 680 (1989)

Argued

Monday, November 28, 1988

Decided

Monday, June 5, 1989

Advocates

Thomas W. Merrill (on behalf of the Respondents)

Michael J. Graetz (on behalf of the Petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Commissioner, 2 vote(s) against
Legal provision: Internal Revenue Code

None

United States v. Hemme

Mon, 05 Jan 2009 17:27:07 +0000

Case Basics

Docket No.

84-1944

Appellee

Hemme

Petitioner Type

Appellee

Appellant

United States

Respondent Type

Appellant

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

476 U.S. 558 (1986)

Argued

Wednesday, March 5, 1986

Decided

Tuesday, June 3, 1986

Advocates

Edward F. Sutkowski (on behalf of Respondent)

Albert G. Lauber, Jr. (on behalf of Appellants)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Internal Revenue Code

None

Dickman v. Commissioner

Mon, 05 Jan 2009 17:29:05 +0000

Case Basics

Docket No.

82-1041

Petitioner

Dickman

Petitioner Type

Petitioner

Respondent

Commissioner

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

465 U.S. 330 (1984)

Argued

Tuesday, November 1, 1983

Decided

Tuesday, February 21, 1984

Advocates

Frank P. Riggs (on behalf of Petitioners)

Lawrence G. Wallace (on behalf of Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Commissioner, 2 vote(s) against
Legal provision: Internal Revenue Code

None

Diedrich v. Commissioner

Mon, 05 Jan 2009 17:30:29 +0000

Case Basics

Docket No.

80-2204

Petitioner

Diedrich

Petitioner Type

Petitioner

Respondent

Commissioner

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

457 U.S. 191 (1982)

Argued

Wednesday, February 24, 1982

Decided

Tuesday, June 15, 1982

Advocates

Norman E. Beal (on behalf of the Petitioners)

Stuart A. Smith (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Commissioner, 1 vote(s) against
Legal provision: Internal Revenue Code

None

Jewett v. Commissioner

Mon, 05 Jan 2009 17:30:34 +0000

Case Basics

Docket No.

80-1614

Petitioner

Jewett

Petitioner Type

Petitioner

Respondent

Commissioner

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

455 U.S. 305 (1982)

Argued

Tuesday, December 1, 1981

Decided

Tuesday, February 23, 1982

Advocates

Stuart A. Smith (on behalf of Respondent)

James D. St. Clair (on behalf of the Petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Commissioner, 3 vote(s) against
Legal provision: Internal Revenue Code

None

United California Bank v. United States

Mon, 05 Jan 2009 17:11:46 +0000

Case Basics

Docket No.

77-1016

Petitioner

United California Bank

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

439 U.S. 180 (1978)

Argued

Wednesday, October 4, 1978

Decided

Monday, December 11, 1978

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for United California Bank, 3 vote(s) against
Legal provision: Internal Revenue Code

None

Central Illinois Public Serv. Co. v. United States

Mon, 05 Jan 2009 16:34:01 +0000

Case Basics

Docket No.

76-1058

Petitioner

Central Illinois Public Serv. Co.

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

435 U.S. 21 (1978)

Argued

Wednesday, October 12, 1977

Decided

Tuesday, February 28, 1978

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Central Illinois Public Serv. Co., 0 vote(s) against
Legal provision: Internal Revenue Code

None

Commissioner v. Kowalski

Mon, 05 Jan 2009 16:34:05 +0000

Case Basics

Docket No.

76-1095

Petitioner

Commissioner

Petitioner Type

Petitioner

Respondent

Kowalski

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

434 U.S. 77 (1977)

Argued

Wednesday, October 12, 1977

Decided

Tuesday, November 29, 1977

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Commissioner, 2 vote(s) against
Legal provision: Internal Revenue Code

None

Bob Jones University v. Simon

Mon, 05 Jan 2009 17:10:01 +0000

Case Basics

Docket No.

72-1470

Petitioner

Bob Jones University

Petitioner Type

Petitioner

Respondent

Simon

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

416 U.S. 725 (1974)

Argued

Monday, January 7, 1974

Decided

Wednesday, May 15, 1974

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Simon, 0 vote(s) against
Legal provision: Internal Revenue Code

None

Commissioner v. "Americans United" Inc.

Mon, 05 Jan 2009 16:34:38 +0000

Case Basics

Docket No.

72-1371

Petitioner

Commissioner

Petitioner Type

Petitioner

Respondent

"Americans United" Inc.

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

416 U.S. 752 (1974)

Argued

Monday, January 7, 1974

Decided

Wednesday, May 15, 1974

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Commissioner, 1 vote(s) against
Legal provision: Internal Revenue Code

None

United States v. Cartwright

Mon, 05 Jan 2009 17:19:52 +0000

Case Basics

Docket No.

71-1665

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Cartwright

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

411 U.S. 546 (1973)

Argued

Tuesday, January 16, 1973

Decided

Monday, May 7, 1973

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Cartwright, 3 vote(s) against
Legal provision: Internal Revenue Code

None

United States v. Correll

Mon, 05 Jan 2009 17:41:17 +0000

Case Basics

Docket No.

113

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Correll

Respondent Type

Respondent

Heard By

Warren Court (1967-1969)

Decided By

Warren Court (1967-1969)

Opinion

389 U.S. 299 (1967)

Argued

Tuesday, November 14, 1967

Decided

Monday, December 11, 1967

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 3 vote(s) against
Legal provision: Internal Revenue Code

None

Commissioner v. Stidger

Mon, 05 Jan 2009 17:42:07 +0000

Case Basics

Docket No.

173

Petitioner

Commissioner

Petitioner Type

Petitioner

Respondent

Stidger

Respondent Type

Respondent

Heard By

Warren Court (1965-1967)

Decided By

Warren Court (1965-1967)

Opinion

386 U.S. 287 (1967)

Argued

Monday, January 16, 1967

Decided

Monday, March 20, 1967

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Commissioner, 3 vote(s) against
Legal provision: Internal Revenue Code

None

Commissioner v. Tellier

Mon, 05 Jan 2009 17:43:58 +0000

Case Basics

Docket No.

351

Petitioner

Commissioner

Petitioner Type

Petitioner

Respondent

Tellier

Respondent Type

Respondent

Heard By

Warren Court (1965-1967)

Decided By

Warren Court (1965-1967)

Opinion

383 U.S. 687 (1966)

Argued

Thursday, January 27, 1966

Decided

Thursday, March 24, 1966

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Tellier, 0 vote(s) against
Legal provision: Internal Revenue Code

None

Rudolph v. United States

Mon, 05 Jan 2009 17:41:58 +0000

Case Basics

Docket No.

396

Petitioner

Rudolph

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Warren Court (1962)

Decided By

Warren Court (1962)

Opinion

370 U.S. 269 (1962)

Argued

Tuesday, April 3, 1962

Decided

Monday, June 18, 1962

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 2 vote(s) against
Legal provision: Writ Improvidently Granted

None

Commissioner v. Bilder

Mon, 05 Jan 2009 17:41:39 +0000

Case Basics

Docket No.

384

Petitioner

Commissioner

Petitioner Type

Petitioner

Respondent

Bilder

Respondent Type

Respondent

Heard By

Warren Court (1962)

Decided By

Warren Court (1962)

Opinion

369 U.S. 499 (1962)

Argued

Thursday, March 29, 1962

Decided

Monday, April 30, 1962

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Commissioner, 1 vote(s) against
Legal provision: Internal Revenue Code

None

United States v. Davis

Mon, 05 Jan 2009 17:41:56 +0000

Case Basics

Docket No.

190

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Davis

Respondent Type

Respondent

Consolidation

No. 268

Heard By

Warren Court (1962)

Decided By

Warren Court (1962)

Opinion

370 U.S. 65 (1962)

Argued

Wednesday, March 28, 1962

Decided

Monday, June 4, 1962

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for United States, 0 vote(s) against
Legal provision: Internal Revenue Code

None

United States v. Patrick

Mon, 05 Jan 2009 17:41:38 +0000

Case Basics

Docket No.

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Patrick

Respondent Type

Respondent

Heard By

Warren Court (1962)

Decided By

Warren Court (1962-1965)

Opinion

372 U.S. 53 (1963)

Argued

Wednesday, March 28, 1962

Reargued:

Thursday, December 6, 1962

Decided

Monday, February 18, 1963

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for United States, 2 vote(s) against
Legal provision: Internal Revenue Code

None

United States v. Gilmore

Mon, 05 Jan 2009 17:38:44 +0000

Case Basics

Docket No.

Petitioner

United States

Respondent

Gilmore

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

372 U.S. 39 (1963)

Argued

March 27-28, 1962

Reargued:

December 5-6, 1962

Decided

Monday, February 18, 1963

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for United States, 2 vote(s) against
Legal provision: Internal Revenue Code

None

Commissioner v. Lester

Mon, 05 Jan 2009 17:37:56 +0000

Case Basics

Docket No.

376

Petitioner

Commissioner

Petitioner Type

Petitioner

Respondent

Lester

Respondent Type

Respondent

Heard By

Warren Court (1958-1962)

Decided By

Warren Court (1958-1962)

Opinion

366 U.S. 299 (1961)

Argued

Tuesday, April 25, 1961

Decided

Monday, May 22, 1961

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Lester, 0 vote(s) against
Legal provision: Internal Revenue Code

None

United States v. Kaiser

Mon, 05 Jan 2009 16:30:14 +0000

Case Basics

Docket No.

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Kaiser

Respondent Type

Respondent

Heard By

Warren Court (1958-1962)

Decided By

Warren Court (1958-1962)

Opinion

363 U.S. 299 (1960)

Argued

Wednesday, March 23, 1960

Decided

Monday, June 13, 1960

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Kaiser, 3 vote(s) against
Legal provision: Internal Revenue Code

None

Commissioner v. Duberstein.

Mon, 05 Jan 2009 16:30:21 +0000

Case Basics

Docket No.

376

Petitioner

Commissioner

Petitioner Type

Petitioner

Respondent

Duberstein.

Respondent Type

Respondent

Consolidation

No. 546

Heard By

Warren Court (1958-1962)

Decided By

Warren Court (1958-1962)

Opinion

363 U.S. 278 (1960)

Argued

Wednesday, March 23, 1960

Decided

Monday, June 13, 1960

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Commissioner, 1 vote(s) against
Legal provision: Internal Revenue Code

None

Cammarano v. United States

Mon, 05 Jan 2009 16:29:12 +0000

Case Basics

Docket No.

Petitioner

Cammarano

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Consolidation

No. 50

Heard By

Warren Court (1958-1962)

Decided By

Warren Court (1958-1962)

Opinion

358 U.S. 498 (1959)

Argued

Wednesday, November 19, 1958

Decided

Tuesday, February 24, 1959

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Internal Revenue Code

None

Peurifoy v. Commissioner

Mon, 05 Jan 2009 16:29:08 +0000

Case Basics

Docket No.

Petitioner

Peurifoy

Respondent

Commissioner

Heard By

Warren Court (1958-1962)

Decided By

Warren Court (1958-1962)

Opinion

358 U.S. 59 (1958)

Argued

Thursday, October 16, 1958, Monday, October 20, 1958

Decided

Monday, November 10, 1958

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Commissioner, 3 vote(s) against
Legal provision: Internal Revenue Code

None

Fidelity-Phila. Trust Co. v. Smith

Mon, 05 Jan 2009 16:29:45 +0000

Case Basics

Docket No.

130

Petitioner

Fidelity-Phila. Trust Co.

Petitioner Type

Petitioner

Respondent

Smith

Respondent Type

Respondent

Heard By

Warren Court (1957-1958)

Decided By

Warren Court (1957-1958)

Opinion

356 U.S. 274 (1958)

Argued

Thursday, January 30, 1958

Decided

Monday, April 28, 1958

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Fidelity-Phila. Trust Co., 3 vote(s) against
Legal provision: Internal Revenue Code

None

United States v. Calamaro

Mon, 05 Jan 2009 16:28:50 +0000

Case Basics

Docket No.

304

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Calamaro

Respondent Type

Respondent

Heard By

Warren Court (1957)

Decided By

Warren Court (1957-1958)

Opinion

354 U.S. 351 (1957)

Argued

Monday, March 4, 1957

Decided

Monday, June 17, 1957

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Calamaro, 1 vote(s) against
Legal provision: Internal Revenue Code

None

Putnam v. Commissioner

Mon, 05 Jan 2009 16:28:48 +0000

Case Basics

Docket No.

Petitioner

Putnam

Petitioner Type

Petitioner

Respondent

Commissioner

Respondent Type

Respondent

Heard By

Warren Court (1956-1957)

Decided By

Warren Court (1956-1957)

Opinion

352 U.S. 82 (1956)

Argued

Wednesday, October 17, 1956

Decided

Monday, December 3, 1956

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Commissioner, 1 vote(s) against
Legal provision: Internal Revenue Code

None

Commissioner v. Lobue

Mon, 05 Jan 2009 16:25:25 +0000

Case Basics

Docket No.

373

Petitioner

Commissioner

Petitioner Type

Petitioner

Respondent

Lobue

Respondent Type

Respondent

Heard By

Warren Court (1955-1956)

Decided By

Warren Court (1955-1956)

Opinion

351 U.S. 243 (1956)

Argued

Tuesday, March 6, 1956

Decided

Monday, May 28, 1956

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Commissioner, 2 vote(s) against
Legal provision: Internal Revenue Code

None