Coyle v. United States
United States Court of Appeals for the Fourth Circuit
415 F.2d 488 (1968)
- Written by Daniel Clark, JD
Facts
The three sons of George Coyle Sr. (plaintiff) owned 100 percent of the stock of Coyle Realty Company (Realty). Coyle also owned a majority of Coyle & Richardson, Inc. (C & R). Coyle and his sons collectively owned approximately 95 percent of C & R. Coyle transferred a portion of his C & R shares to Realty in exchange for cash. Coyle treated the transfer as a sale and reported a long-term capital gain on his tax return. The Internal Revenue Service (IRS) (defendant) treated the transfer as a dividend, taxable as ordinary income, and assessed additional tax. Coyle paid the increased assessment and sued the IRS for a refund. The district court ruled in favor of Coyle, and the IRS appealed.
Rule of Law
Issue
Holding and Reasoning (Sobeloff, J.)
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