Early v. Commissioner
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Early v. Commissioner, 445 F.2d 166 (5th Cir. 1971)[1] was a United States income tax case, holding that an agreement between taxpayers and heirs of decedent—pursuant to which taxpayers received a joint life interest in income from the trust estate in return for the surrender of stock allegedly given to them by the decedent—was actually a compromise of the taxpayers' disputed right to the stock, and since they claimed the stock as donees, they were to be treated as having acquired their life estate in that capacity for federal income tax purposes.
Quick Facts Early v. Commissioner, Court ...
Early v. Commissioner | |
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Court | United States Court of Appeals for the Fifth Circuit |
Full case name | Allen M. Early and Jeannette B. Early v. Commissioner of Internal Revenue |
Decided | May 21, 1971 |
Citation(s) | 445 F.2d 166 |
Case history | |
Subsequent history | Rehearing denied June 16, 1971; certiorari denied, 92 S.Ct. 100, October 12, 1971. |
Court membership | |
Judge(s) sitting | James P. Coleman, Robert A. Ainsworth Jr., John Cooper Godbold |
Case opinions | |
Majority | Godbold, joined by a unanimous court |
Laws applied | |
Internal Revenue Code, 26 U.S.C. § 273 |
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