JULEO, INC.
v.
COMMISSIONER OF INTERNAL REVENUE

U.S. | 1973-12-10
No. 73-542
Mr. Justice White and Mr. Justice Blackmun would grant certiorari.
414 U.S. 1103 Supreme Court of the United States (1973) Caution
Cited by 11 cases

Opinion

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Citator

Cited By (11 total)

  • Bennett v. White, 865 F.2d 1395 (3d Cir. 1989)
    …); Witter v. Pennsylvania Nat’l. Guard, 462 F.Supp. 299, 306 n. 9 (E.D.Pa.1978). The reasoning of these cases is consistent with the result reached by this court prior to Edelman v. Jordan in Carter v. Butz, 479 F. 2d 1084 (3d Cir.), cert. denied, 414 U.S. 1103, 94 S.Ct. 737, 38 L.Ed.2d 559 (1973). We conclude that these authorities are sound. It is one thing for a state to insist that the Eleventh Amendment prevents retroactive relief which affects its fisc. It is quite another to insist that the state c…
  • …held for sale within the ordinary course of a taxpayer’s trade or business is a question of fact. See Jersey Land & Development Corp., 539 F. 2d at 315; Juleo, Inc. v. Commissioner, 483 F. 2d 47, 50 (3d Cir.) (Gibbons, J., dissenting), cert. denied, 414 U.S. 1103, 94 S.Ct. 737, 38 L.Ed.2d 559 (1973); Heebner v. Commissioner, 280 F. 2d 228, 231-32 (3d Cir.), cert. denied, 364 U.S. 921, 81 S.Ct. 285, 5 L.Ed.2d 260 (1960).7 PSLC argues that the Tax Court’s finding was clearly erroneous because it was inconsiste…
  • Sons v. Commissioner OF Internal Revenue, 497 F.2d 862 (3d Cir. 1974)
    …able as an issue of law and is not subject to the clearly erroneous rule. See discussion and cases cited in Juleo, Inc. v. Commissioner of Internal Revenue, 483 F. 2d 47, 50-51 (3d Cir. 1973) (Gibbons, J., dissenting on other grounds), cert. denied, 414 U.S. 1103, 94 S.Ct. 737, 38 L.Ed.2d 559 (1973) in particular, Kaltreider v. Commissioner of Internal Revenue, 255 F. 2d 833, 837 (3d Cir. 1958), and Pennroad Corp. v. Commissioner of Internal Revenue, 261 F. 2d 325 (3d Cir. 1958), cert. denied 359 U.S. 958, 7…

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