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United States Vs. Davis
Cites for this judgment
- US Supreme Court
- Mar 23, 1970
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U.S. 301 (1970) U.S. Supreme Court United States v. DavisSearch
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U.S. 301 (1970) United States v. DavisSearch
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in response to this Court's decision that pro rata stock dividends do not constitute taxable income, Eisner v. MacomberSearch
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aimed at tax avoidance schemes, and sought only to determine whether such a scheme existed. See, e.g., Commissioner v. QuackenbosSearch
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Bains v. UnitedSearch
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Ballenger v. UnitedSearch
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See Northup v. UnitedSearch
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Smith v. UnitedSearch
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Commissioner v. EstateSearch
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b)(1). Hasbrook v. UnitedSearch
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has unequivocally adopted the Commissioner' view, and held irrelevant the motivation of the redemption. See Levin v. CommissionerSearch
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Hasbrook v. UnitedSearch
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F.2d 811 (1965). The First Circuit, however, seems almost to have come to that conclusion, too. Compare Wiseman v. UnitedSearch
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States, 371 F.2d 816 (1967), with Bradbury v. CommissionerSearch
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b)(1) to the business motivation of a distribution and redemption. See, e.g., Commissioner v. BerenbaumSearch
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Kerr v. CommissionerSearch
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Heman v. CommissionerSearch
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United States v. FewellSearch
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F.2d 496 (C.A. 5th Cir.1958). See also Neff v. UnitedSearch
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that the business purpose be related not to the issuance of the stock, but to the redemption of it. See Commissioner v. BerenbaumSearch
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Commissioner v. GordonSearch
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See Levin v. CommissionerSearch
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Commissioner v. BerenbaumSearch
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Bradbury v. CommissionerSearch
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U.S. Supreme Court United States v. DavisSearch
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Commissioner v. QuackenbosSearch
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Commissioner v. EstateSearch
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Compare Wiseman v. UnitedSearch
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Neff v. UnitedSearch
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See Commissioner v. BerenbaumSearch
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Commissioner v. GordonSearch
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