[DOWNLOAD] "Henry T. Patterson Trust V. United States" by United States Court Of Appeals For The Sixth Circuit ~ Book PDF Kindle ePub Free
eBook details
- Title: Henry T. Patterson Trust V. United States
- Author : United States Court Of Appeals For The Sixth Circuit
- Release Date : January 22, 1984
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 67 KB
Description
The United States of America appeals the decision of the United States District Court for the Northern District of Ohio, Eastern Division, in favor of plaintiff-appellee Henry T. Patterson Trust (Trust) in this action for a refund of federal income taxes with interest. The Trust, by its Trustee, the Reeves Banking & Trust Company (Reeves), instituted this action for a refund of $115,747.98 in federal income taxes paid by the Trust in 1979 for the year 1976, plus interest of $15,805.94 which had accrued as of 1979. The Internal Revenue Service had assessed such taxes on the basis that the amount paid to the Trust for the redemption of all of the Trust's shares in the Puritan Laundry and Dry Cleaning Company (Puritan) should be taxed as a dividend, and not as a sale of stock. The record reveals the following facts.