Legal Opinion
Consolidated Edison Company of New York, Inc. v. United States
Court of Appeals for the Second Circuit
Decided November 23, 1993No. 1622, Docket 93-6028PublishedCited by 4 opinions
1Opinion of the Court
WALKER, Circuit Judge:
The United States appeals from a judgment entered in the United States District Court for the Southern District of New York (Kimba M. Wood, Judge), granting summary judgment to Consolidated Edison Company of New York, Inc. (“Con Edison”) on its $1,207,087 tax refund claim. This appeal considers the proper treatment under the Internal Revenue Code of discounts Con Edison received from New York City (the “City”) in exchange for prepayment of its real property taxes in 1975 and 1978. The district court ruled that the discounts were exempt from taxation as interest on…
2Cases cited18 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- United States v. AndersonSupreme Court of the United States · 1926
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
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3Cited by4 opinions
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- City of Columbus v. CommissionerUnited States Tax Court · 1998