HINES v. UNITED STATES

No. 72-2731.

477 F.2d 1063 (1973)

Harry H. HINES, Jr., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

May 2, 1973.


Attorney(s) appearing for the Case

James P. Knight, Jr., Thomas A. Bell, Jackson, Miss., for plaintiff-appellant.

Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Atty., Jane Edmisten, App. Div. Tax Div., Dept. of Justice, Washington, D. C., H. M. Ray, U. S. Atty., Oxford, Miss., Jack D. Warren, Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellee.

Before RIVES, GOLDBERG and MORGAN, Circuit Judges.


GOLDBERG, Circuit Judge:

This is an appeal from the denial of a claim by taxpayer, Harry H. Hines, Jr., for a recovery of income taxes and interest assessed and paid for the years 1966 and 1967. Although this appeal involves only taxpayer's personal income tax liability, the controlling question is one of corporate taxation: Whether the proceeds from the sale of property that had been distributed to taxpayer by a family-owned corporation were properly imputed to the...

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