(Download) "Reynolds V. Commissioner Of Internal Revenue" by United States Court Of Appeals For The Sixth Circuit * Book PDF Kindle ePub Free
eBook details
- Title: Reynolds V. Commissioner Of Internal Revenue
- Author : United States Court Of Appeals For The Sixth Circuit
- Release Date : January 16, 1988
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 70 KB
Description
The question in this case is whether the doctrine of judicial estoppel ought to be applied against the Commissioner of Internal Revenue on the issue of who, as between the petitioner and the petitioner's former spouse, is to be taxed on a certain capital gain. The gain resulted from the sale, in 1977, of leasehold interests and mineral rights in a coal mine. In 1983 the Commissioner determined that sale proceeds nominally received by petitioner's wife were attributable to petitioner. Earlier, however, in bankruptcy proceedings involving the wife, the Commissioner had entered into a bankruptcy court-approved stipulation binding the wife to recognize and pay taxes on the gain. We conclude that under the unusual facts presented here the doctrine of judicial estoppel does apply, and it precludes the Commissioner from repudiating the position on which the court-approved stipulation was based.
 "Reynolds V. Commissioner Of Internal Revenue" by United States Court Of Appeals For The Sixth Circuit * Book PDF Kindle ePub Free){kind=link}