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In the Matter of Aldecoaotalora

18 I&N Dec. 430 (B.I.A. 1983)
In the Matter of Aldecoaotalora

9 Cited authorities

  1. Lutwak v. United States

    344 U.S. 604 (1953)   Cited 932 times   3 Legal Analyses
    Distinguishing between an actual “agreement to conceal” and “an afterthought by the conspirator for the purpose of covering up”

  2. Gregory v. Helvering

    293 U.S. 465 (1935)   Cited 1,446 times   7 Legal Analyses
    Holding that when the form of a transaction does not comport with its substance, the substance of the transaction controls for tax liability purposes

  3. Comm'r v. Court Holding Co.

    324 U.S. 331 (1945)   Cited 829 times   1 Legal Analyses
    Holding that the Tax Court was justified in relying on the economic substance doctrine to "attribut[e] the gain from the sale to respondent corporation."

  4. Commissioner v. Tower

    327 U.S. 280 (1946)   Cited 566 times   1 Legal Analyses
    Holding that federal law governs whether parties formed partnership for tax purposes

  5. Boyter v. C. I. R. Service

    668 F.2d 1382 (4th Cir. 1981)   Cited 35 times
    Noting that the court has discretion "as to whether to employ the Maryland certification procedure"

  6. Boynton v. Commissioner

    649 F.2d 1168 (5th Cir. 1981)   Cited 20 times

    No. 80-5069. July 9, 1981. Rogers Meisel, Robert O. Rogers, David S. Meisel, Palm Beach, Fla., for petitioners-appellants. M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Acting Chief, Appellate Sect., Richard W. Perkins, Daniel F. Ross, Attys., Tax Div., U.S. Dept. of Justice, N. Jerold Cohen, Chief Counsel, Internal Revenue Service, Washington, D.C., for respondent-appellee. Appeal From the Tax Court of the United States. Before HILL, and FRANK M. JOHNSON, Jr., Circuit Judges, and SCOTT

  7. Davis v. C.I.R

    585 F.2d 807 (6th Cir. 1978)   Cited 12 times

    No. 76-2283. Argued February 9, 1978. Decided October 27, 1978. H. Stennis Little, Jr., Little, Thrailkill Owen, John B. Owens, Jr., Nashville, Tenn., for appellants. Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Timothy B. McBride, Tax Div., U.S. Dept. of Justice, Washington, D.C., Meade Whitaker, Chief Counsel, I.R.S., Washington, D.C., for appellee. Appeal from the United States Tax Court. Before EDWARDS and KEITH, Circuit Judges, and PECK, Senior Circuit Judge. PECK, Senior Circuit

  8. McLat v. Longo

    412 F. Supp. 1021 (D.V.I. 1976)   Cited 5 times
    Rejecting Eighth Amendment challenge to administrative procedures designed to ferret out sham marriages and prevent unwarranted conferral of "immediate relative" status, and observing that "deportation and exclusion" have been held to be outside protection of that amendment

  9. Section 1153 - Allocation of immigrant visas

    8 U.S.C. § 1153   Cited 1,223 times   10 Legal Analyses
    Determining an applicant's age as " the age of the alien on the date on which an immigrant visa number becomes available for such alien . . . but only if the alien has sought to acquire the status of an alien lawfully admitted for permanent residence within one year of such availability; reduced by (B) the number of days in the period during which the applicable petition . . . was pending"