Cowden v. Commissioner
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Cowden v. Commissioner, 289 F.2d 20 (5th Cir. 1961),[1] outlined the factors used to determine whether something received is a cash equivalent, in other words, whether something received is taxable when it was received or when it was assigned. The court observed two main doctrines in determining when something is taxable. The court relied on the doctrines of constructive receipt and cash equivalence while reiterating that substance rather than form should control income tax laws.
Quick Facts Cowden v. Commissioner, Court ...
Cowden v. Commissioner | |
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Court | United States Court of Appeals for the Fifth Circuit |
Full case name | Frank Cowden, Sr. and wife Gladys Cowden v. Commissioner of Internal Revenue |
Decided | April 12, 1961 |
Citation(s) | 289 F.2d 20 |
Court membership | |
Judge(s) sitting | Elbert Tuttle, Richard Rives, Warren Leroy Jones |
Case opinions | |
Majority | Jones, joined by a unanimous court |
Laws applied | |
Internal Revenue Code | |
Keywords | |
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