Legal Opinion
Altria Group, Inc. v. United States
Court of Appeals for the Second Circuit
Decided September 27, 2011No. Docket 10-2404-cvPublishedCited by 28 opinions
1Opinion of the Court
POOLER, Circuit Judge:
In this tax refund suit, Altria Group, Inc. claims $24,337,623 in depreciation, interest, and transaction cost deductions for the tax years 1996 and 1997. The claimed deductions result from Altria’s participation in nine leveraged lease transactions with tax-indifferent entities. In each transaction, Altria leased a strategic asset from a tax-indifferent entity; immediately leased back the asset for a shorter sublease term; and provided the tax-indifferent entity a multimillion dollar “accommodation fee” for entering the transaction and a fully-funded purchase option to…
2Cases cited28 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
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3Cited by28 opinions
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- Bank of New York Mellon Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2015
- Consolidated Edison Co. of New York, Inc. & Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2013
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