Legal Opinion
A.E. Staley Manufacturing Company and Subsidiaries v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided July 2, 1997No. 96-1940PublishedCited by 38 opinions
1Opinion of the Court
RIPPLE, Circuit Judge.
The predecessor of A.E. Staley Manufacturing Company and Subsidiaries (“Staley”) paid investment bankers in connection with an unsuccessful effort to defeat a hostile tender offer. On its federal income tax return, the company claimed a deduction for the fees paid to the bankers. The Commissioner of Internal Revenue disallowed the claimed deduction and issued a notice of deficiency. Staley’s predecessor then filed a petition in the United States Tax Court challenging the disallowance. The Tax Court agreed with the Commissioner and held that the expenses were capital…
2Cases cited32 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- United States v. GilmoreSupreme Court of the United States · 1963
27 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- U.S. Freightways Corp., F.K.A. Tnt Freightways Corp., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
- Pnc Bancorp, Inc., Successor to First National Pennsylvania Corporation v. Commissioner of Internal Revenue (Tax Court No. 95-16002) Pnc Bancorp, Inc., Transferee of Assets of First National Pennsylvania Corporation v. Commissioner of Internal Revenue (Tax Court No. 95-16003) Pnc Bancorp, Inc., Successor to United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16109) Pnc Bancorp, Inc., Transferee of Assets of United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16110) Pnc Bancorp, Inc., as (I) Successor to First National Pennsylvania Corporation, (Ii) Transferee of Assets of First National Pennsylvania Corporation, (Iii) Successor to United Federal Bancorp, Inc., and Subsidiaries, and (Iv) Transferee of Assets of United Federal Bancorp, Inc., and SubsidiariesCourt of Appeals for the First Circuit · 2000
- Norwest Corp. v. CommissionerUnited States Tax Court · 1999
- Charles Reynolds and Beatrice Reynolds v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2002
- Wellpoint, Inc. v. CommissionerCourt of Appeals for the Seventh Circuit · 2010
33 more not listed; retrieve them via the Exa API.