[DOWNLOAD] "Hutton v. United States" by United States Court Of Appeals For The Sixth Circuit " Book PDF Kindle ePub Free
eBook details
- Title: Hutton v. United States
- Author : United States Court Of Appeals For The Sixth Circuit
- Release Date : January 05, 1974
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 62 KB
Description
In this case the government appeals from a judgment of the United States District Court for the Western District of Tennessee, refunding to taxpayer plaintiffs Thomas H. Hutton and Betty Hutton $36,872.66 in federal income taxes and interest which the trial court found had been improperly assessed against them for the years 1964-1966. The basis for the refund was the trial courts determination that certain payments received by the taxpayer during those years in retirement of corporate notes held by him were received in exchange for capital assets and, thus, were taxable as capital gain to the extent they exceeded the taxpayers basis under Section 1232(a) (1) of the Internal Revenue Code of 1954 as amended. The government contends the payments were dividend income under Sections 301 and 316 of the Code.
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