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· 5/28/1974

Commissioner v. National Alfalfa Dehydrating & Milling Co.

Citations

  • 417 U.S. 134
  • 94 S. Ct. 2129
  • 40 L. Ed. 2d 717
  • 1974 U.S. LEXIS 59
  • 33 A.F.T.R.2d (RIA) 1347

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

  • holding that a taxpayer has discretion in structuring a transaction but is bound by its tax consequences
  • referring to “the established tax principle that a transaction is to be given its tax effect in accord with what actually occurred and not in accord with what might have occurred”
  • “[W]hile a taxpayer is free to organize his affairs as he so chooses, nevertheless, once having done so, he must accept the tax 20 (...continued
  • \a transaction is to be given its tax effect in accord with what actually occurred and not in accord with what might have occurred\
  • transaction is to be given tax effect in accord with what actually occurred and not in accord with what might have occurred
  • taxpayer must accept unfavorable tax consequences of chosen transaction form, whether contemplated or not

Source: CourtListener parenthetical corpus (CC0).

Judges: Blackmun, Burger, Douglas, Brennan, White, Marshall, Powell, Rehnquist, Stewart, Court'S

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This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.