Legal Opinion
Guy F. Atkinson Company of California and Subsidiaries v. Commissioner of Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided June 25, 1987No. 85-7715PublishedCited by 16 opinions
1Opinion of the Court
TANG, Circuit Judge:
Guy F. Atkinson Co. [“Atkinson”] appeals from a determination by the United States Tax Court of a $4,115,981 tax deficiency. We have jurisdiction under 26 U.S.C. § 7482. We affirm.
FACTS AND PROCEEDINGS:
Atkinson’s subsidiary, Walsh Construction Co., was managing partner in a joint venture, Water Tunnel Contractors [“WTC”] 1 WTC was organized to construct a water tunnel for New York City. WTC submitted winning bids approximating $222 million for the contracts related to the water tunnel project. In its 1970 federal partnership income tax return, WTC elected to report income…
2Cases cited8 opinions
- United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
- Isbrandtsen Co. v. JohnsonSupreme Court of the United States · 1952
- National Contracting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1939
- Thomas Take and Janice Take v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1986
- National Contracting Co. v. CommissionerUnited States Board of Tax Appeals · 1938
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- In Re Windmill Farms, Inc., Debtor. Vanderpark Properties, Inc. v. David L. Buchbinder, Trustee of Windmill Farms Management Company, Inc.Court of Appeals for the Ninth Circuit · 1988
- Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
- Matter of FaberUnited States Bankruptcy Court, S.D. Iowa · 1987
- Margaret E. Doolin and Claire Welt, Individually and as Co-Executors of the Estate of Thomas J. Doolin, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1990
- Chase Lumber & Fuel Co., Inc. v. ChaseCourt of Appeals of Wisconsin · 1999
11 more not listed; retrieve them via the Exa API.