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Dixon Vs. United States

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  • US Supreme Court
  • May 03, 1965

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44 entries 3 linked 41 unlinked
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  1. Watson Vs. Commissioner US Supreme Court · May 18, 1953
  2. United States Vs. Kaiser US Supreme Court · Jun 13, 1960
  3. Automobile Club of Michigan Vs. Commissioner US Supreme Court · Apr 22, 1957
  4. Dixon v. United
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  5. States - 381 U.S. 68 (1965) U.S. Supreme Court Dixon v. United
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  6. States, 381 U.S. 68 (1965) Dixon v. United
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  7. were assertedly made in reliance on the published acquiescence of the Commissioner of Internal Revenue in Caulkins v. Commissioner
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  8. Original issue discount is not entitled to capital gains treatment under the 1939 Internal Revenue Code. United States v. Midland-Ross
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  9. JUSTICE BRENNAN delivered the opinion of the Court. This case involves the issue decided today in United States v. Midland-Ross
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  10. Circuit, 333 F.2d 1016. We brought the case here on certiorari, 379 U.S. 943, to resolve a conflict with United States v. Midland-Ross
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  11. the notes, they relied upon the Commissioner's published acquiescence in the Tax Court's decision in Caulkins v. Commissioner
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  12. Commissioner has discretion to apply the withdrawal of the acquiescence retroactively, cf. Automobile Club of Michigan v. Commissioner
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  13. in the tenth year. See United States v. Midland-Ross
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  14. involved in Caulkins, and issued by the particular issuer there involved. In Automobile Club of Michigan v. Commissioner
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  15. where a taxpayer may have relied to his detriment on the Commissioner's mistake. See Manhattan General Equipment Co. v. Commissioner
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  16. Manhattan General Equipment Co. v. Commissioner
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  17. the tax lawfully due under the statute. We cannot agree with petitioners that Automobile Club of Michigan v. Commissioner
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  18. Stat. 680, 714-715, to eliminate a difference in treatment between sales and retirements. See, e.g., Fairbanks v. United
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  19. erroneously to carry forward a distinction, and to give more favorable treatment to retirements. See United States v. Midland-Ross
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  20. f) language of Page 381 U. S. 79 retirement, and consequently was inapplicable to a sale. See Paine v. Commissioner
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  21. United States v. Midland-Ross
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  22. Certificates could not rationally be distinguished from other discounted securities. Cf. American State Bank v. United
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  23. Schwartz v. Commissioner
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  24. basis taxpayer is required to report discount earned before the final disposition of an obligation. See United States v. Midland-Ross
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  25. Helvering v. Reynolds
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  26. Miller v. United
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  27. Lynch v. Tilden
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  28. U. S. 299 , 363 U. S. 308 (concurring opinion). See also Schuster v. Commissioner
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  29. Exchange Parts Co. of Fort Worth v. United
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  30. City Loan & Savings Co. v. United
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  31. Brecklein v. Bookwalter
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  32. Connecticut Railway & Lighting Co. v. United
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  33. U.S. Supreme Court Dixon v. United
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  34. Caulkins v. Commissioner
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  35. Internal Revenue Code. United States v. Midland-Ross
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  36. See United States v. Midland-Ross
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  37. In Automobile Club of Michigan v. Commissioner
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  38. See Manhattan General Equipment Co. v. Commissioner
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  39. Fairbanks v. United
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  40. See Paine v. Commissioner
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  41. Cf. American State Bank v. United
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  42. Helvering v. Reynolds
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  43. Miller v. United
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  44. Schuster v. Commissioner
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